Gee! What could go wrong?
They’re going at it all wrong. Mandating design rather than performance. In the 1960s we had the European Cibie halogen headlights which were FAR superior to the Guide type sealedbeams, but were illegal under DOT rules. We used them anyway, but where I lived then we had to swap back to sealed-beams to pass mandatory vehicle inspection every six months. Still stuck on stupid, is the DOT.