Yes, AFAIK, the current Model 3 headlights in EU are diminished to meet the local regulations because those are not equipped with automatic leveling and possibly a washer system. So it's actually NA market cars that have more efficient headlights as it is and I doubt there will be any change to NA headlights because of NHTSA.
And yes, in EU the current model 3 headlights compare pretty poor to all the bells and whistles that competitors put in their cars. For example VW, Audi, Mercedes have very advanced headlights, i.e. dynamic low beam patterns changing in conjuction with the vehicle speed, headlights turning in corners etc., AND dynamic high beams/dynamic light assist/smart light assist (led projectors or matrix led tech), masking the oncoming traffic and vehicles in front of you while you can drive with high beams on constantly. This is not "auto high beams" that just turn on and off.
Its interesting to see what these new "EMEA" headlights stand for, since they could be adopting some new tech (illegal in NA
) required here to enhance the current headlights shipped here. We'll see.