FYI, anything with exemptions (usually aerospace applications, and elements that simply can't be substituted) can still be called RoHS.
For example, barium is quite toxic (when soluble), and it's unavoidable in type 2 ceramic capacitors (barium titanate). So, these capacitors are always by exemption, at least on their barium content. (I would assume single elements or chemicals can be exempted, individually. So that's not to say that you can go ahead and solder barium-rich capacitors with lead, just because they have one kind of exemption.)
It's still weird putting it on leaded solder, which, in and of itself, clearly has an excessive amount in its composition, and isn't necessarily intended for exempted applications. (Composition is necessary to discuss, because harmful materials can be diluted in the assembly process. You'd have to read the standard to see exactly which levels of assembly are considered a whole component, for purposes of composition. For example, a packaged semiconductor might have lead solder die-attach, or lead ball flip-chip construction. But a PCBA might not be allowed to use leaded solder, even if the overall concentration of the assembly is satisfactory. I don't know offhand where they draw the line here.)
Tim