The approval is only given in conjunction with headlights where the optics have been tested with the LED. This what the TÜV verifies and approves.
This is the reason why the exact E-number is mentioned in the document and the correct headlight required on the car.
The alternative to the LEDs is the Osram Nightbreaker 200 (H4 and H7 available). Much cheaper, no approval required and a vast improvement.
It also does not annoy oncoming traffic as much as the LED - but then again: almost all the of new cars have LED lights....
If the approved headlamp reflector/body was dedicated to an LED light source, i.e. it was sold as an LED headlamp package with appropriate E marking I can understand it's approval. However, and please correct if I'm wrong Tim, the headlamp body in this case was designed and originally approved for a lower light output halogen bulb

I further fail to understand why such retro LED conversions are so popular given their price. There are now a variety of full LED approved headlamp packages available, such as those fitted to CX series, Land Rovers etc. with most including a DRL or bright position light option, for similar or lesser price!