High impedance or low efficiency dynamic or planar drivers, or electrostats that need a lot of voltage. The thing is every design has its advantages and disadvantages and sometimes in the course of designing a headphone that measures well enough in response, once price is factored in, you have to make concessions on a lot of other things, like efficiency, or going for higher impedance so it won't be too much of a problem if it has impedance swings (but if it's being driven by a chip that makes 5mW at 32ohms, then obviously you'd have a problem).
Don't worry about amping the ones you have now though.