May I direct you to Section 16 - Exterior Projections.
It reads:
Where a vehicle is not fitted with a roof the areas referred to in section
12 Annex 1 shall be assessed to the requirements of this section. The
exempted areas detailed in annex 1 of section 12 still apply to roofless
vehicles if a windscreen is fitted.
Which I believe means that those areas are not exempt on a roofless windscreenless car, but tested against the exterior projection rules
