Yes, agreed. The manufacturer does not claim or mark it DOT.
But it meets ECE.
It does seem stupid. Especially because the way it was first told to us, by very enthusiastic promotors of the Cibie's and other top quality E-code lamps was that the ece standards were better.
But now we know a little better. They're not better; they're different.
What would be better if the two could resolve the differences in approach and testing.
Dan Stern summarizes the differnces here Best headlights for 9004 bulbs? '95 Mazda Mx6 - Page 2
Fortunately, in the past few years many states have come to accept e-code lamps as replacements.
U. S. Federal legality of ECE type-approved auxiliary lamps
Updated Hella "Super" 7" H4 Headlights
FWIW the older sealed beams are legal but dont have DOT or SAE molded into the lenses.
Also one that bit me was Hella makes an H4 lamp assembly marked DOT but actually was only for Motorcycle use. The high/low split is really annoying. I gave those away and bought the DOT version back when the Barracuda was still registered and inspected in NJ. Much better.
This is a 6012 sealed beam that was on one of my cars.
On the back of this Westinghouse is a small inkstamp - 6014 Superbeam DOT
Daniel Stern Lighting Consultancy: Lens Codes
1985 SAE headlight codes and their industry designations in the table at the bottom here
Performance Requirements for Motor Vehicle Headlamps
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