Are these 200 sites being hosted by you for others individual parties? Can you give us some specifics about what your doing? Initially I'd worry less about the resources in this case and more about separation of concerns and administrative overhead.
One thing to think about is that SQL Express databases are capped at 10GB for data size so that might be your determining factor right there. If your single database grows beyond that you're pretty much hosed.
More on SQL Server edition specifics here.
EDIT:
With 200 potentially 1GB databases you'll be better off going with Standard, but I would also consider using individual databases there as well. Express has a 1GB limit on memory while Standard is limited only by the host OS which will give you the option of much much more memory to throw at SQL. As for which uses less memory, it's hard to say not knowing your data architecture. Within that single database would you have 200 copies of each table or keep the data for all 200 sites in one copy of the tables? You'd be looking at differences in index sizes there which can affect memory consumption. SQL will try to load as much of your database into memory as it can and is allowed to by configuration.
JohnThePro also makes good points about the other features available in Standard that Express doesn't support.