If you have a fault where the resistance is between 7660Ω and 2300Ω then the RCD would (probably) not trip in <0.2 s however it is not required to according to BS7671. This would be a similar situation to MCBs that will not trip in the required time if the fault current is low; similarly how do you know and MCB will trip in the time stated, you do not know, you are relying on the manufacturers making them to standard. It is not (in standard situations) safe to test this compliance.
You are quite right, however we still record the disconnection time on a 100mA at 1x and 1x only. This is the disconnection time at its rated current, which is higher than 200ms, therefore it will not comply.