Reading the document is interesting. There are a number of exemptions.
EEE intended to protect national security and/or for military purposes
Products where electricity is not the main power source
Products where the electrical or electronic components are not needed to fulfil the primary function
Electrical and electronic equipment that is part of another type of equipment
The last one has an interesting example:
Examples of such equipment would be lighting or entertainment equipment for use in vehicles, trains or aircraft. This type of equipment would be excluded as it is designed to be part of a product that falls outside the scope of the Directive
It looks like machine tools could be exempt:
To large-scale stationary industrial tools. (This is a machine or system, consisting of a combination of equipment, systems, products and/or components installed by professionals, each of which is designed, manufactured and intended to be used only in fixed industrial applications.)
I think this is what would affect the OP(my bold):
For the purposes of the RoHS Regulations, a maximum concentration value of up to 0.1% by weight in homogeneous materials for lead, mercury, hexavalent chromium, PBB and PBDE.
Page 16 has a decision tree.
The exceptions are interesting as well. There's a metals exemption for lead:
6. Lead as an alloying element in steel containing up to 0.35% lead by weight, aluminium containing up to 0.4% lead by weight and as a copper alloy containing up to 4% lead by weight
12L14 shows .15 to .35 in the source I consulted, so it would be OK. The exemptions are very interesting.
Please remember all this is just some guy on the internet......