As I noted based on my "cruise control" (HDA) testing, on my Canadian I5, the brake lights do activate even with a very minor amount of braking force, when using cruise control and picking up speed going down a descent. My testing indicated that the braking force felt much less than level 1 regen, to limit the gradual increase in speed, and the brake lights activated.
In fact the brake lights stayed on, even with no apparent deceleration, to maintain the speed close to the cruise control setting while "rolling" down the descent. Strictly speaking, that shouldn't be necessary, similar to using engine braking instead of physical brakes to limit speed when descending a hill in an ICE.
The same occured when gaining on a car ahead of me in my lane.
I'm not sure if there are any variations in how this is implemented in different countries - I haven'tseen other posts referring to cruise control behaviour, just level 1 vs other level behaviour.
I will be redoing this testing to see if the behaviour is the same, regardless of the regen level set, but in my opinion, under cruise control, HDA should override regen level settings, for the purposes of brake light activation.
I would be happy if the brake lights were consistently activated based on the deceleration rates you describe above.
I've written to Hyundai Canada descriing this behaviour, and will be interested if they agree this is a potential issue. I assume that a software "fix" would be doable, to make it consistent with the "non-cruise control" behaviour, where level 1 regen does no braking.