California Title 24 Cool Roofs: Commercial Project Planning Guide

California’s Building Energy Efficiency Standards—often called Title 24, Part 6—include requirements that can affect commercial roofing projects. The relevant question for an owner is not whether a roof is “cool” in a general sense, but which requirements apply to the particular building and scope.

2025 California Energy Code Timing

The California Energy Commission states that the 2025 Energy Code applies to permit applications submitted on or after January 1, 2026. The Commission publishes the standards, reference appendices, nonresidential compliance manual, forms, and software resources. For a proposed commercial roofing project, permit timing is one input among several that should be reviewed with the project team.

Cool-Roof Terms at a High Level

Solar reflectance describes how much solar energy a roof surface reflects. Thermal emittance describes how effectively a surface releases absorbed heat. Solar Reflectance Index (SRI) is a calculated value that combines reflectance and emittance for certain comparisons. These terms can appear in product literature, ratings, specifications, and code discussions, but they do not establish project compliance on their own.

The Cool Roof Rating Council (CRRC) develops methods for rating radiative properties of roof products and maintains a rated-product directory. A CRRC rating is not a universal product recommendation, a guarantee of building performance, or a determination that a project complies with the Energy Code.

Why Climate Zone and Building Details Matter

California’s requirements can vary by climate zone, building type, roof area, and roof slope. The proposed roof system, insulation, configuration, existing building conditions, and project scope can also affect what needs to be evaluated. Avoid relying on a neighboring property’s solution or a general product statement as a substitute for project review.

Prescriptive and Performance Compliance

At a high level, Energy Code compliance may involve prescriptive requirements, performance approaches, or other applicable provisions depending on the project. The correct pathway and documentation are matters for the project team and applicable authority. Owners can ask who is responsible for the code analysis, what documentation is anticipated, and how the proposed roof assembly is being evaluated.

Reroofing, Alterations, and Repairs

Reroofing, roof reconstruction, and roof renewal may be considered alterations under relevant implementation guidance, while repairs may be treated differently. That distinction should be resolved for the actual scope. A coating project, a replacement project, and a limited repair do not automatically receive the same treatment simply because they occur on the same building.

Questions for Your Project Team

• Which Energy Code version and permit timing apply to the planned work?
• Is the work being evaluated as repair, alteration, reroofing, reconstruction, or renewal?
• What climate-zone, building-type, roof-area, and roof-slope factors are relevant?
• Which product ratings, specifications, calculations, forms, or approvals are required?
• Who will coordinate confirmation with the applicable authority having jurisdiction?

For roofing-scope discussions, visit Commercial Roof Coating or Spray Foam Commercial Roofing. These pages describe service options; they do not determine Energy Code compliance for a specific project.