California Title 24 Cool Roof Requirements for Commercial Buildings: What You Need to Know

California Title 24 Cool Roof Requirements for Commercial Buildings

If you're replacing or restoring a commercial roof in California, you need to comply with the California Energy Commission's Title 24 Cool Roof requirements. Most California commercial roofing contractors will tell you their products comply — but do you know what that actually means, and how to verify it?

Here's a practical guide.

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What Is Title 24?

Title 24 is California's Building Energy Efficiency Standards. Part 6 covers energy efficiency for both residential and non-residential buildings. The Cool Roof provisions within Title 24 require minimum solar reflectance and thermal emittance for roof products installed on conditioned commercial buildings.

The goal is to reduce the urban heat island effect, lower building cooling loads, and reduce California's peak electricity demand.

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The Core Requirements

For low-sloped commercial roofs (slope ≤ 2:12):

Title 24's Prescriptive path requires:

• Aged Solar Reflectance ≥ 0.63 (how much solar energy is reflected)
• Thermal Emittance ≥ 0.75 (how efficiently the roof radiates absorbed heat)

Or an equivalent Solar Reflectance Index (SRI) ≥ 75 (a combined metric).

These requirements apply to:

• New roof installations
• Roof replacements (when more than 50% of the roof area is replaced)
• Re-roofing of existing low-sloped commercial roofs

Important: The aged solar reflectance is the measurement after 3 years of weathering — not the initial "as-installed" reflectance. The CRRC (Cool Roof Rating Council) publishes rated aged values for compliant products.

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Which Roofing Systems Comply?

White single-ply membranes (TPO and PVC): Most white TPO and PVC membranes easily meet Title 24 requirements. Look for CRRC-rated products with aged SR ≥ 0.63. Major manufacturers (Carlisle, Johns Manville, GAF) maintain CRRC-rated product lines.

Silicone roof coatings: High-solids white silicone coatings, including GE Enduris, maintain excellent reflectance over time. Silicone resists dirt pickup better than acrylic coatings — a key advantage since dirty roofs lose reflectance. GE Enduris products are CRRC-listed.

Modified bitumen and BUR systems: Standard dark-colored modified bitumen and BUR do NOT comply with Title 24 Cool Roof requirements. Granule-surfaced white cap sheets and coated BUR systems can comply, but must be specified carefully and verified with CRRC listing.

Metal roofing: Bare galvanized or aluminum metal often does not comply. PVDF-coated white metal panels can comply. Verify CRRC listing.

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The CRRC: How to Verify Compliance

The Cool Roof Rating Council (CRRC) is the independent organization that rates roofing products for solar reflectance and thermal emittance. California requires that products used on Title 24-compliant projects be CRRC-listed.

To verify a product is CRRC-listed:

1. Visit coolroofs.org/rated-products
2. Search by product name, manufacturer, or CRRC product ID
3. Verify the aged solar reflectance meets the Title 24 threshold for your application

Your roofing contractor should be able to provide the CRRC product ID for the specific product being installed, and this ID should appear on your installation documentation and permit application.

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When Do You Need to Comply?

You must comply with Title 24 Cool Roof requirements when:

• Installing a new commercial roof
• Replacing more than 50% of an existing roof
• Re-roofing over an existing system (in most cases)

You may have a compliance pathway exemption when:

• The roof deck is uninsulated (certain agricultural or unconditioned structures)
• The building is a historic structure with compliance exemptions
• The project qualifies for an equipment trade-off under the Performance compliance path

Your contractor should pull a building permit for any commercial roof replacement in California, and the permit application should document Title 24 compliance.

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Title 24 and Roof Restoration

When Restco Roofing performs a silicone roof restoration using GE Enduris, the completed system is CRRC-listed and meets Title 24 Cool Roof requirements. This is an important benefit of restoration over doing nothing with an aging dark-surface roof — the new white silicone surface dramatically improves the building's energy performance while also extending the roof's life.

For commercial buildings with dark-colored existing membranes, the energy savings from switching to a white reflective surface can be meaningful — ENERGY STAR estimates that a cool roof can reduce peak cooling demand by 10–15% in hot climates.

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What Your Contractor Must Provide

When completing a commercial roofing project in California, your contractor should provide:

1. CRRC Product ID for the installed system
2. Aged solar reflectance and thermal emittance values from the CRRC listing
3. Certificate of Compliance (NRCA CF-2R or equivalent documentation for your jurisdiction)
4. Building permit from the local jurisdiction confirming Title 24 compliance

If a contractor tells you they don't need a permit or that Title 24 doesn't apply, be cautious. Commercial roofing in California requires permits in virtually all jurisdictions, and permit-free work exposes you to liability and insurance coverage gaps.

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Questions?

Restco Roofing handles Title 24 documentation and permitting for all commercial roofing projects in Southern California. Every project includes complete compliance documentation. Contact us at 949-324-4452 or schedule a free inspection online.