I have worked with a number of customers to prove that materials supplied comply with the RoHS directive. The directive states that no more than the maximum concentration value by weight in homogeneous materials shall be tolerated. What this means is that the limits do not apply to the weight of the finished product, or even to a component, but to any single substance that could (theoretically) be separated mechanically. Therefore in answer to your question, it applies only to the solder, as this could be separated in the future.