Thanks Rick. Here's the text from the 2003 edition. The part that raises questions is the requirement for the parts to be within 1/16" of the same plane.
404.2.9 Door Surface. Door surfaces within 10 inches (255 mm) of the floor, measured vertically, shall be a smooth surface on the push side extending the full width of the door. Parts creating horizontal or vertical joints in such surface shall be within 1/16 inch (1.6 mm) of the same plane as the other. Cavities created by added kick plates shall be capped.
EXCEPTIONS:
1. Sliding doors.
2. Tempered glass doors without stiles and having a bottom rail or shoe with the top leading edge tapered at no less than 60 degrees from the horizontal shall not be required to meet the 10 inch (255 mm) bottom rail height requirement.
3. Doors that do not extend to within 10 inches (255 mm) of the floor.
The Commentary makes it seem like the product does meet the intent though:
This provision is intended to assist people who will be attempting to open a door from the “push” side of the door. Some persons with disabilities push against doors with their chairs or walkers to open them. Applied kick plates on doors with closers reduce the required maintenance by withstanding abuse from wheelchairs and canes. By providing a smooth surface (one with no more than 1/16 inch (1.6 mm) variation), a user can be assured that the door will slide along the leg rest of a wheelchair, their foot or the bottom of a walker or crutch that is being pushed against the door without catching. A vertical bar or rod on the latch side of a door is likely to interfere with the opening of a door when the feet or footrest are pressed against a door to open it [see commentary Figure C404.2.9(a)]. To be effective, a kick plate must cover the door width, less approximately 2 inches (50 mm), up to a height of 10 inches (255 mm) from the floor [see commentary Figure C404.2.9 (b)]. This range will allow for the most common height settings for wheelchair foot plates. The sentence requiring that cavities be capped will typically be applied when the kick plate is added onto a glass or panel door and the bottom rail of the door is less than 10 inches (255 mm) in height.