Is Apple playing games with its environmental certifications?

Apple claims on its website that it is RoHS (pronounced "rose") compliant.

RoHS is a fairly straightforward European environmental regulation and, generally, mandates limits on the amount of certain toxic substances  (lead, mercury, cadmium, and certain flame retardants) used in many electronics products.

Generally, the maximum permitted concentrations are 0.1% or 1000 ppm (except for Cadmium, which has an even more severe limit).

So, 0.1% is the limit. 

Now here's what's interesting.  There is a separate environmental law in China, referred to as "China RoHS", which currently mandates that if a manufacturer is above the 0.1% limit, they have to make a disclosure in the product's manual (it currently only mandates disclosure, not the actual elimination of the toxic substance).

Which brings me to this disclosure hidden in the back of the current iPAD 2 docking station user manual:

To translate, this document says that the circuit board and the "enclosure" (whatever that means) have lead concentrations higher than 0.1% (denoted by the "x").

In addition, the "10" with a circle on the bottom is mandated by China's law to describe how long the manufacturer believes that the product will not degrade or leach the toxic substance (the number 10 means 10 years).

Which brings us to the perplexing question:  Why is Apple saying they are RoHS compliant, when in fact, they are separately disclosing that they aren't?

It appears that Apple is playing games.