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I didn't have this problem because my BRZ had just over 100 miles when I got it. However, this can happen to any vehicle when the battery is disconnected, or when a car is brand new. There are several emissions related sensors in a vehicle that need to be operational for a given amount of drive time, otherwise the smog test cannot be completed.
The problem is that there's no exact science as to how many miles you need to put on until the sensors "set", so smog techs typically just say drive it another 50-100 miles. Some websites give you techniques on how to drive to re-enable the sensors faster, but I never found them to work.
On the WRX I recently sold I disconnected the battery to change back the radio. I didn't realize that doing this would reset my emissions sensors. Therefore I had to drive the car for nearly 200 miles before the sensors would "set" so that I could smog the car for resale. I went to 3 different smog shops, and they all said the same thing. I guess this requirement was enacted to keep guys from just resetting their ecu's to help them pass smog.
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