Dear Dr. Ron:
The first exemption in the RoHS Annex is that of mercury in compact fluorescent lamps cannot exceed 5 mg per lamp.
I would like to inquire what is the definition of "compact fluorescent lamps"?
I look forward to your prompt and valuable reply.
This article by Finn and Oullette
should be helpful. The EU, as is typical, gives no precise definition.
As always, remember that the exemption for mercury does not mean that this product is exempt for the other RoHS materials or WEEE. So your work has only been reduced 15%.