LED 7" Round Headlights Upgrade!!

What you're saying is basically right.
You may be OK with Vixen.
Here's how it works.
When the car was made the manufacturers used parts that met standards set out in federal regs and industry standards.
Fed regs for safety are Federal Motor Vehicle Safe Standards (FMVSS) which often also reference SAE and other standards.
My understanding is that lamps, marker lenses etc are not sent in for approval. Rather the manufacturers test and mark them to identify what standards they meet. Only if there was a problem would the government do an independent check.

When we drive a personal car on public roads we need to maintain them to the state's standards.
Most (all?) states allow lamps made to newer standards.
If the markings on the lamp are legit (in other words the manufacturer actually can prove it actually meets the standard for using the marking) and the beam pattern is correct, you're probably completely legal.

The Cibie E code headlamps are not DOT approved. Period. If there's an E on the headlamp, that's the European code. It's stupid, really, because they should be DOT approved. Their jeweling focuses the light on low beam in a wedge pattern getting bigger toward the right side of the road. They literally blast road signs to pieces. They also have a sharp light cutoff line on low beam. That's very considerate of other drivers. On high beam, they are a different story. They focus light down the road, not a bunch of wasted light on the road right out in front of the car giving the illusion of "better lighting". They actually ARE better lighting. But as I said, as long as the headlamps are aimed properly, there is little chance of trouble.

Lastly, keep in mind the market is slam flooded with cheap lighting of all kinds. An "upgrade" to LED bulbs in some H4 style headlamps for instance, will result in really poor performance, because halogen and LED bulbs do not shine light in the same way. The headlamps need to be LED specific, as LED lights in a halogen headlamp housing will result in a scattered and non focused light pattern. The two are entirely different as far as light output. I've tried both dedicated LED headlamps and H4 halogen conversions and so far I am slap sold on good quality H4 halogen headlamps. Both Cibie and the Hella H4 conversions are really nice with the Cibie coming out on top. But they need to be the older Cibie lamps. The newer ones leave some to be desired.