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Since these are the exact sizes and specs for the factory optional 369M and 309 staggered set ups (with the correct tire sizes) they should work fine as long as the wheels have the correct hub diameter to match the X3 (72.5mm). The published offset spec. is 45 +/- 2 mm, but obviously BMW is allowing 38 mm offset wheels to be used without spacers. Probably, they want to enhance the apparent staggered "look" by narrowing the track at the front slightly. It's also possible that they compensate for the offset change by using a little less toe-in at the front (possibly different alignment specs for the staggered set up).
The difference (at the front) is only 7 mm - Although most commonly sold in 12, 15, 20 and 25 mm offsets, Eibach does make a 5mm spacer with a 72.5 ring.
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