What is a “special tool”? A Philips screwdriver is pretty clearly not, but is a T-5 Torx? A security T-5? A Tri-wing? A Pentalobe?
> (50) 'basic tools' means a screwdriver for slotted heads, a screwdriver for cross recess screws, a screwdriver for hexalobular recess heads [Torx], a hexagon socket key, a combination wrench, combination pliers, combination pliers for wire stripping and terminal crimping, half round nose pliers, diagonal cutters, multigrip pliers, locking pliers, a prying lever, tweezers, magnifying glass, a spudger and a pick;
(Excepted devices can require "commercially available tools" which is defined exactly as you'd expect.)
> Commercially available tools are considered to be tools available on the market to all end-users without the need for them to provide evidence of any proprietary rights and that can be used with no restriction, except health and safety-related restrictions.
Imagine the lasting havoc the Nazis could have wrought if they adopted a + instead of a swastika