they're not foglights, they're DRLs. Too many people can't tell the difference, though.
IMO, it's an excellent idea if it means PC Plod needs to get onto his hands and knees and reads the rest of the imprinted E1 authorisation. Better not have anything else wrong, though...
I've had no problems with the law and DRLs + sidelights (as required here) + tail lights (no numberplate) in Germany, Poland, Sweden or here. Three of those require DRLs, the other they're optional.
How to tell if it's fog or DRL? Well, one's running 55W and the other 6W. Yes, it's only around half as bright, but, dammit, quit flashing lights at me telling me I have fogs on. I don't. It gets very, very annoying and I never had the issue with two obvious lights there. I got flashed by the police a couple of months back. My lights, though halogen, are e-marked R87 and work correctly. No issue.
Alternative: LED versions - the 90mm round ones fit perfectly where the original fogs go. Hella's LEDayline are also pretty cool but are not permitted to be used as sidelights without removing / disabling the originals and ensuring an installation height over 350mm from the road surface. This is virtually impossible to do with stock height and the foglight cutouts as they're too rounded to fit the unit in. You can't use the central grille because they'd then be too close together. An alternative would be to cut the top slat out of the central grille and then move them as far as possible outwards.
Fogs are also tolerated as DRLs here, tolerated being the operative word.
Bret