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That's the only way for the 4th place team to miss out. by NDMike2001

Generally England gets 4 (with the fourth place team going through qualification).

A Europa OR CL champion (not in top 4) would give them a 5th.

A Europa AND CL champion (not in top 4) still gives them 5, but the 4th place in the league would go to Europa next year.

EDIT: I read the original post wrong. A team could never make it into CL by simply placing 5th in the league. Most people usually ask what happens when a team outside of the league qualifiers wins a championship. And that's what I thought the question was. Because it's a relatively new rule that allows for the 5th team. We'll call it the Spuds Exception.