They are a requirement for Xenons with 35W, factory fitted or not! There is a limit on what light intensity requires them... for that reason Osram offer 25W ones for retrofit - they don't require auto levelling and washers.
I would assume if they have 'e' mark and it does not say they need AL/W they will be supplied with 25W Xenon burners (and were tested for use with these)....
These 25W are designed not to dazzle other road users (as much), however they will still need to be fitted to headlights that are meant to be used with Xenons, i.e. not Halogen headlights.