Currently, yes they are.
But the Comission is also revising this piece of legislation, as they are in the process for the recast of the RoHS directive.
On March 14 they have agreed on a consildated text which you can find here: https://register.consilium.europa.eu/pdf/en/11/st07/st07851.en11.pdf
If you look to the new Annex A on page 73, there you will find the statement on the inclusion of Medical Devices.
I suggest you go through this text to have a better understanding on what is coming up next.
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