RoHS compliance for kits containing EEE and non-EEE finished products

My company sells a tool kit that contains several different finished products. The majority of the BOM is non-EEE hand tools with the only two EEE products being a digital caliper and multimeter. After reading through the RoHS 2 FAQ document and further searching online I haven't been able to come to a conclusion if all of the products within the kit would need to be RoHS compliant or only those two products.

Based on these two sections of the FAQ below I feel like I could argue that the hand tools can be considered separated from the digital calipers and multimeter similar to the wardrobe and light which is different than the accessories that are specifically intended to be used with power tools.

"For the example of a wardrobe with lights, even if sold as a single unit, a distinction between the piece of furniture and the electric/electronic device the piece is or can be equipped with has to be drawn. If the lighting is EEE in itself and both the lighting and the wardrobe can be separated and used as fully functional separate products, only the electric/electronic equipment (the lighting) is in the RoHS 2 scope. The furniture itself would then be outside the scope.

This scenario is different from the example of power tools, lamps and many other types of EEE, most of which are already in the scope of RoHS 1 and are comprised of various detachable electric/electronic and non-electric/electronic parts, which are however only fully functional in combination. These parts are simply integral parts of EEE and have to meet the respective requirements. This is for example reflected in various existing exemptions for non-electric EEE parts."

TLDR: Are all of the components of a kit containing multiple EEE and non-EEE finished products within the scope of RoHS or would only the EEE finished products be within scope?

I would look at the definitions in the Directive:
Article 2
Scope
1. This Directive shall, subject to paragraph 2, apply to EEE falling within the categories set out in Annex I.

Article 3
Definitions
For the purposes of this Directive, the following definitions shall apply:
(1) ‘electrical and electronic equipment’ or ‘EEE’ means equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields and designed for use with a voltage rating not exceeding 1 000 volts for alternating current and 1 500 volts for direct current.

Non-EEE items sold in a tool kit are not EEE within scope of RoHS if they have a function that is independent of EEE.

A table lamp is a single item that is EEE because the non-electrical parts are integral to the function of the electrical parts.

In the example in the FAQ, the wardrobe is still a wardrobe if you took the light out of it, and it has a function. A table lamp has no function if you removed the electrical parts and cord.

I would not consider your non EEE tools to be within scope of RoHS

Thank you for your response. That is what I had assumed when I initially researched the directive but a compliance expert from a testing agency said otherwise after I sent him the webpage listing with pictures and the product description.

I've obviously not seen that list

I often recommend documenting the reasoning behind the decision as to whether a product is in or out of scope of one or more CE marking Directives - it forms part of your defence of "due diligence" if challenged and is useful to review at a later date if new guidance or understanding of "state of the art" occurs.