I can't completely agree with your "short" account of the spacer history. I have found them on many non-US market vehicles. This also includes US models that were made before the DOT bumper height and strength regulations, e.g., the earliest 2.8l e9's through 1972. The spacers came in different thicknesses too. Other Non-US models E3/02 had them too, even without the bigger bumpers.
Realoem for the E9 clearly depicts the spacers, but does not provide a BMW part number - even for the Dot compliant vehicles. Notice the part identified as "15" below. In fact, nos. 15, 16 and 17 do not appear to be listed on any of the models - including the later big bumpered ones. ("guide support" 31331101663 is listed). Having explored this issue a long time ago, I believe the spacer is listed by some sources as a "Flat Washer" (part number 31331106059). In some instances, realoem indicates next to the part: "If necessary." This does not account for the different thicknesses I have seen. Compliance with bumper height regulations (if really an issue) or headlamp height (more regulations) could have been less expensively accomplished (for the manufacturer) by reducing front tire pressure. :wink:
In any case, realoem's lack of a specific listing or notation for the spacers on the E9 could be an oversight or more likely something that was considered a superseded - nonessential part.