Yeah, all the file tree view/list view stuff, shell namespace etc. etc. is implemented in shell32.dll, so we should probably compare with explorer.exe + shell32.dll. Everything else are basic widgets and OS interaction which clearly exists in both environments so shouldn't be counted.

And with that it is still only 4.27MB+6.81MB = 11.08MB on my system. So yeah, the bloat is real no matter how you look at it.