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It would be nice to find out when that particular airframe had it's major repair work undertaken. Because then we would at least know at what point the repair depot deemed it necessary to repaint the cockpit interior from RLM02 to RLM66. That would mean that by this point RLM66 was in fact the favoured colour for Bf109 interiors.
Thing is I can't see there being a shortage of any colour at that stage of the war. Especially at a factory or major repair depot. I agree that it could be any old grey, just like the upper surface greens could have been any old green.... But we know that was not the case. The evidence is there for this dark application of paint to be RLM66. It was available and in use during this period for this specific purpose on other aircraft. If you was a betting man what RLM colour would you say it was Rogi?
But there is plenty of visual information in this topic to suggest otherwise....
I don't think the application of RLM66 in Bf109E cockpit interiors was particularly widespread. Well not to the point that all Bf109Es produced after a certain date had their interiors catergorically painted in RLM66. It could be that only certain manufacturers or repair depots were using it from mid-late 1940 but to suggest that it was impossible and did not happen is being far too narrow minded. Luftwaffe paints, camouflage, and markings go far beyond what it states in the official RLM documents. There will always be photographs that contradict the official rules....