I'm not going to say don't do it...I freely admit to having no knowledge of the legalities regarding vehicular lighting matters in the USA. If it is indeed illegal, then there is no point in pursuing any argument on this matter.
The legality of this is a very valid stand-point.
I do like my driving lights, bright, white and oh so much of it.
Not the same as his system but a means to an end. BUT they only come with high beam when you have them switched into the circuit and we often have 10 000 m of flat open country to see lots of animals, roads that simply disappear, bulldust, washouts etc.
You cannot use them with low.
Just dandy! but suited to country driving here anyway. It is a NEED not a want, here.
However, you are getting into some tricky territory...that of the three dimensional aspect of the various paraboloids of reflectors, the nature of the beam, coupled with the fresnel lens effects which are not so obvious to the uninitiated but incorporated into ALL vehicle lighting lens forms.
However, I am certain the relative area that the reflector system plays has little bearing on whether or not it is suitable for the HID system it is more related to the appearance of a vehicle. If they (the manufacturer) can use a smaller lens/reflector system and enhance the look of their product then of course, they will do so.
All the best with your venture. If you proceed, I certainly would like to read how you get on.
If there are those who wish to argue this on a genuine engineering basis then I suggest a separate thread might be the place but there is little point if it is indeed illegal.
Cheers
Auberon