100 Cell cats do not meet ADR's. There are 200 cell cats that do meet adr's and are therefore EPA legal. You could pass a EPA test with a 100 cell if your engine tune is spot on. 200 Cell is as good as you can get and thump it to the testers at the same time, if you want to go 100 cell, why bother, just put a straight pipe for max flow, its just as illegal or do as I have on my GTR and run a 5" cat body with all the guts removed for max flow. Coppers look and they see a cat, if they ask for a EPA test, a cheap 400 cell one gets bolted in for a few hours. Both my fake cat (straight pipe) and legal cat have identical flanges made up, just undo a few bolts, pull the sensor off and bolt the other one on, less than 5 minutes work. Edit; forgot to mention, no cat, 100 cell or 200 cell makes no/very little difference in sound, cats dont muffle the sound, they have no sound absorbing properties.