My understanding is that if it has anything to do with an end-product that you would classify as "electronics", then it applies.
For example, we make doming/lensing resins. Electrical/electronic? No. Used to dome a label that goes on something electrical/electronic (i.e., a phone, camera, etc.)? Maybe...if so, then we're required to follow RoHS.
Clarification of the *very* end use of your product should point you in the right direction.
Hope this helps,
-R.