Swapped to these

[VladTepes]

The ADR was changed, yes, so that new ones no longer need to comply but my understanding is that any bike which was sold during the period that ADR was in place does still need to comply.  I could be wrong though.

As far as visibility is concerned. In THEORY if you are riding with the sun behind you - oncoming traffic looking into the sun and you do NOT have a light on then you are silhouetted and MAY be seen. It's less likely you'll be seen if that silhouette is broken up by a headlight being on.

In practice however I don;t think it makes any difference.  The main upside do always on headlights as far as I can see is no way of forgetting to turn it on at night...