The other headers that I'm aware of have the o2 sensor bungs for the sammy and trackick. Why they wouldn't pass, I don't know. I've heard that the California Air Resource Board certification, a.k.a. the C.A.R.B. sticker, does cost a small fortune. I think that is why only Thorley has it. It's not like the Jeep crap, or anyone else's for that matter, that has to have air injection ports or anything like that. There is nothing special about the headers.
Where I live in Idaho, we go through the emissions testing once a year. I have never been failed because of the header. I have failed on unrelated matters like the cat was bad or the o2 sensor wasn't reading right, or the egr valve was shot. But not because of the header. And they will fail you because of a visual inspection here.