Easy. In the US, the sealed beam is a replacement part. In Europe, the reflector/glass assembly is part of the car. Only the bulb is replaceable.
Yes, that's how it works in the USA too. Older cars with sealed beams replace the entire assembly - bulb, reflector, and lens are one integrated unit with connectors on the back. Newer cars have the reflector and lens as a standalone component, "part of the car" as you put it, and the bulb replaces in the back. That's why I said:
Sealed beams are an entire form factor. There's no "socket" to hold a standalone halogen bulb even if the connectors were compatible. If the UK compels you to replace sealed beams with standalone bulbs, there must be a market for some sort of retrofit "body" with the same form factor as the original sealed beam unit. Then the halogen bulb would screw into this body. That's how halogen bulbs are done in the USA... the body is semi-permanent and includes the reflector and lens. The replaceable bulb inserts from the back and has an o-ring to keep the interior of the body clean and dry.
My question, again, is: How do you replace a sealed beam in the UK with a halogen bulb? To be excruciatingly explicit, when you remove the sealed beam you remove the reflector and lens too. Now you have your nice new fancy LEGALLY COMPELLED halogen bulb, and you screw it into... what? The car doesn't have a reflector nor a lens anymore. Do they also sell aftermarket reflector+lens bodies that match the form factor of the now-missing sealed beam? There are a lot of different form factors for sealed beams, so they'd need a whole lot of aftermarket reflector+lens assemblies to match. Is that how they do it? If not, to what do you attach the halogen bulb when there is no reflector nor lens in the car anymore?
The reason for banning sealed beams in Europe is their miserable beam pattern and low light output.
Interesting that they compel replacement even in older cars. I can't think of an equivalent requirement here in the States. Old engines can still drive around just fine, they're not required to install EFI or a new engine or anything. Old products are sort of grandfathered in, you're not punished due to the whims of some recently passed law.
If you follow US car forums, you'll see that a favorite modification is replacing the sealed beams with E-codes (although not allowed in all states).
Yes, swapping out for halogens or xenon or, more recently, LED's is popular. But not compulsory. You must have operational headlights of course, that's always been true, but the ones that came with the car (which, by definition, were compliant with requirements at the time of production) remain legal forever and you simply maintain them to the original specs or better.