Actually the "reflector" is the silver painted area at the back of the light assembly. It is silver, not black, to reflect the near 360 degree output of the incadescent bulb towards the lens, which then refracts and diffuses the light in the proper directions.
Here in Manitoba, we are facing a major problem with lighting systems that do not conform to the DOT standards, and it can affect our ability to register, safety, and insure our vehicles for "on-road" use. I doubt that we are the only ones.
I am not saying that your product is not better, however, I would be very upset in a litigious way if an insurance claim on my vehicle was denied due to something like this. What you are being told in a technical way is simple