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.
Yup! The thing moulded into the lens to reflect red light back at the headlamps shining on it is called a "retroreflector" or "reflex".
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.
Bigtime. Some of the bigger chunks of the problem are "HID kits" installed in halogen headlamps, LED taillamp conversions, and used vehicles imported from Japan. The province of BC retained me to write their vehicle lighting inspection manual not long ago. Big project, big manual, lots of pictures, all with reference to Canada Motor Vehicle Safety Standard 108, Federal Motor Vehicle Safety Standard 108, and applicable SAE, ECE, and JIS standards. It's possible I might know one or two things about what I'm talking about here.
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 "Cover your ***"
That's it exactly. Very simple: the North American system doesn't require pre-approval by a government-accredited lab before you can sell your regulated auto parts. It's up to you as the manufacturer to do whatever-all is necessary to shield yourself from liability arising from the use of your products on the public roads. "Any reasonable person can see they're terrific" will get laughed out of court immediately. Test results objectively demonstrating conformance, on the other hand, will win the day. Cover your aѕѕ!