As far as I know the reasoning behind washers being required on HIDs in the EU is because if the headlights get dirty, the extremely bright focused area of light from the projector then gets diffused on the dirty headlight potentially dazzling oncoming road users. Evidently they also decided that below 2000 lumen is not bright enough to do the same thing
It's a usual loophole situation that makes very little sense!
So the fact that the light cannot get out so you can see something is not as important. Nice regulation...
