So why did my 2015 5 series have mandated headlight washers yet a 2017 with LED headlights did not?
Dunno.
A 2018 F30 3 Series is rated at 7,500lm, but looking at some used UK examples I couldn't see any washers on quite a few. Some did have them, some had blanking plates in place, others were completely devoid.
There are as many sources online arguing they are brighter as there are that argue they are not, so I am not sure how accurate the information you have is.
It's an average.
Individual examples can be either side of that. My own Xenons were nowhere near 3200lm.
We do know, however, that cars with headlights brighter than 2000 lumens must be fitted with a headlight washer system. We also know almost every car with xenon headlights has a headlight washer system and most cars with LED headlights do not...
Then their alignment must be utterly ******, then and the Mfrs and MoT centres need to do their bloody jobs.
On the other hand, 1999lm is still pretty ******* bright and if that beam is being offset by dirty lights, it's still a problem.
If they're over 2000 lumens, legally they must have a washer system fitted - the fact many cars with factory LED headlights don't have washers these days would indicate the output is often under 2000 lumens.
Manufacturers never lie though, right?
Except that those who want to impress with big number will often combine high and low beam values, while those who want to undercut can state output per LED/chip rather than the combined unit. This is one trick they've picked up from other LED industries, although you'd think they'd pick up on the beam alignment tricks too....
As for testing...
"Do LED headlamps require washers / self levellers?
Headlamp washing and levelling systems are a legal requirement and required if the LED headlamp or high intensity discharge lamp has a luminous intensity exceeding 2,000 lumens.
If the luminous intensity isn’t marked on the lamp, a tester won’t be able to tell if these systems are needed. In this case, the headlamps will be treated as ordinary lamps and the vehicle can be passed as they don’t need washers or levelling devices fitted".
DVSA’s Customer Service Centre answers hundreds of MOT related calls and emails daily from testers and members of the public. Here are some of the most frequent questions and answers they’re getting from MOT garages.
mattersoftesting.blog.gov.uk
So if you use unmarked bulbs/lamps, the regulations don't give a ****...
If you're talking about aftermarket retrofit bulbs, then a) obviously people could be fitting absolutely anything and they're already not meant to do that and b) those lumen claims are almost 100% certainly total horse****.
Both OEM and AM are a concern at this point.