Originally the answer was NO. However, most states do not have an exhaustive inspection program like England's MOT. Our state did have a difficult inspection system, but it's been gradually watered down and now only has to be performed for 25+ yera old cars. On the plus side, the old ones become exempt from emissions (smog) testing.
As for compliance with euro lamps, I don't believe any inspector working for this state is smart enough to catch them. If the lights turned on, and dipped when you pulled the lever, that would be enough for them. Next please!
Obviously there was a lot of legal wrangling that went into the headlight approvals in this country. For many years (1967 to 1986, to be exact) cars were required to use sealed beams. That meant 4 round (like a 265) 4 square (81-85 240) 2 round (76 242) or 2 square (fortunately never on a Volvo). That was it- no glass covers, no replaceable bulbs, just sealed beams. In 1986, the federal government relented and allowed any shape of reflector and lens, within certain size guidelines. Since then, it's been deregulated further mainly as a result of European lamp development. We now get BMW and M-B cars with those brilliant arc-lights and UV lights and blue lights and all kinds of stuff.
I would say the E-code lamps have plenty of precedent here now, in OEM designs. However, they were never certified during the time of 240 production... so technically they're not legal.
Like I said I doubt any DMV inspector is bright enough (get it?) to catch them and write them up. In fact I challenge any inspectors listening to competently handle the legalities of alternate types of factory lighting. Very tough to discern what's legal for all types of cars. It brings up a whole host of things no one wants to get into. Can I use 4 round lights instead of 4 rectangular? Can I put the factory fog light kit on my 164? It's going to come down to whether an inspector is paying attention, had a good breakfast, needs to go to the bathroom, feels cranky.... I'd bet these lamps get through inspection 95% of the time at least. And if there really WAS an inspection issue in your area, you'd do this: take the car in for inspection, stock, pass, then change them out. Very simple to skirt that requirement.
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Rob Bareiss, New London CT ::: 86 244DL, 87 244DL, 88 744GLE, 91 244: 808K total