Or just do as the cheap Chinese companies do and stamp DOT on the housing and call it good. Even though there is literally no cutoff line with low beams. LOLYes, I should have worded that differently. I didn't mean that they submit headlights to NHTSA for approval, but in my mind I was thinking of the manufacturer submitting their headlight to a third party for compliance testing. They can of course do the compliance testing in-house.
Either way, they are self-certifying (stating) that their headlight is compliant, and can provide the necessary documentation for proof.
I found a couple on Amazon that have the DOT stamp but in the reviews they show no cutoff at all and blind other drivers.