Well, it would technically apply to any enemy that has an armor rating. That being said, very few bad guys have any real armor, and even fewer (if any) have any armor related perks. Therefor, the Skull Crusher/Limb Splitter perks are of limited use. However, I have taken them with my current character that does not use any smithing and it does help, especially with boss level enemies, which at least usually are wearing some armor.