It is commonly assumed that in ultrastrong laser fields, when the strong field parameter of the laser field $xi$ is larger than one, the electron radiation is well described by the local constant field approximation (LCFA). We discuss the failure of this conjecture, considering radiation of an ultrarelativistic electron interacting with strong counterpropagating laser waves. A deviation from LCFA, in particular in the high-frequency domain, is shown to occur even at $xigg 1$ because of the appearance of an additional small time scale in the trajectory. Moreover, we identify a new class of LCFA violation, when the radiation formation length becomes smaller than the one via LCFA. It is characterized by a broad and smooth spectrum rather than an harmonic structure. A similar phenomenon is also demonstrated in the scenario of an electron colliding with an ultrashort laser pulse. The relevance to laser-plasma kinetic simulations is discussed.
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