It is LED, and we had to test to IEC 62471. Funny you should mention not depending on light energy in favor of current because I have been gently trying to offer this as a resolution in light of the difficulties of capturing a good, repeatable measurement with high intensity LED without resorting to very expensive equipment that requires a lot of technical skill to operate.

But I'm pretty new to a lot of this, so I'm not sure how hard to press the issue.