Does Your LA Reroof Pass Title 24 in 2026?
California's 2025 Energy Code (Title 24 Part 6) took effect January 1, 2026 — and it changed how reroof projects in Los Angeles are evaluated for compliance. The biggest practical impact: more reroofs now trigger cool-roof requirements, and "like-for-like" replacement defenses no longer work for most material upgrades. Here's the technical version made readable.
What Title 24 Part 6 is
Title 24, Part 6 is the California Building Standards Code section governing energy efficiency in residential and commercial buildings. The 2025 edition (effective January 1, 2026) is the seventh major revision since 1978. It covers HVAC, lighting, insulation, windows, water heating, and — relevant here — roofing.
The roofing portion focuses on cool-roof compliance: minimizing absorbed solar heat, reducing cooling loads, and improving urban heat-island performance. For LA's hot summers (Climate Zones 6, 8, 9), the standards directly affect what roof materials are legal for new construction and qualifying alterations.
The three key numbers
Three CRRC-certified values determine compliance:
- Solar Reflectance (SR): ratio of reflected sunlight (0-1 scale). Higher = cooler.
- Thermal Emittance (TE): rate of heat release from surface (0-1 scale). Higher = cooler.
- Solar Reflectance Index (SRI): combined metric. Higher = cooler.
For LA Climate Zones 6, 8, 9, residential reroof minimums per the 2025 code:
- Low-slope roofs (≤2:12): aged SR ≥ 0.63 AND aged TE ≥ 0.75, OR SRI ≥ 75
- Steep-slope roofs (>2:12): aged SR ≥ 0.20 with supplementary compliance options (often satisfied via PVDF cool-roof coating)
The values must be aged values — meaning the CRRC-certified 3-year weathered performance, not the initial out-of-box values. Initial values are typically higher; the aged value is what counts for compliance.
What changed in the 2025 code
The biggest shift is the tightening of the "alteration" definition. Under the 2022 code, many LA reroofs qualified as "like-for-like" replacement and could skip cool-roof requirements. Under the 2025 code, more reroofs now trigger compliance:
- Material changes (e.g., asphalt → metal, tile → metal) automatically trigger Title 24 compliance — no like-for-like defense.
- Same-material replacements (e.g., asphalt → asphalt) trigger if the existing roof is more than 30% replaced; minor patch jobs may still qualify as like-for-like.
- Adding solar to an existing roof can trigger compliance review of the underlying roof.
- Structural changes affecting roof area (additions, dormers) trigger full compliance.
Practical impact: if you're upgrading from asphalt to metal in 2026, you're definitely in the cool-roof rules. Plan for it.
Which roof materials pass
Metal — generally passes with PVDF coating
- Standing seam with PVDF (Kynar 500/Hylar 5000) cool-roof formulation: aged SR ranges 0.30-0.70 depending on color. Light colors (off-white, weathered gray, light bronze) hit 0.63+ easily. Dark colors require specialty "cool dark" pigment systems.
- Stone-coated steel with cool-roof coating: aged SR 0.30-0.45 depending on color. Light tile/sand colors meet requirements.
- Bare galvalume: initial SR around 0.65 but aged drops significantly. Often fails 3-year aged requirement.
- Copper: initial SR around 0.70 but oxidation drops aged SR significantly. May fail aged requirements unless specifically tested.
Tile
- Clay tile (natural color): typical aged SR 0.30-0.45. Light/cream colors pass; terra-cotta and dark red can fail.
- Concrete tile (cool-roof formulation): aged SR 0.25-0.55 depending on color and pigment system.
Asphalt
- Standard asphalt shingles: aged SR 0.05-0.20. Almost always fail Title 24 — but compliance allows alternative paths via insulation, vents, or other building envelope measures.
- "Cool" asphalt shingles with reflective granules: aged SR 0.25-0.40. Specific products from GAF, CertainTeed, Owens Corning are certified.
How compliance is documented
Your contractor's permit submission must include:
- Product spec sheet with manufacturer name, product line, model, color, and CRRC product ID
- CRRC product certificate downloaded from coolroofs.org showing aged SR, TE, and SRI values
- Cool roof labels shipped with the roofing material — physical labels affixed to product packaging serve as field verification during inspection
- Compliance form CF-1R/CF-2R (California Form Energy Compliance Building Energy 1 and 2 Reports) completed by the contractor and submitted with the permit application
If any of these documents are missing or unclear, plan check returns the application for corrections — typically 1-2 week delay per round trip.
Alternative compliance paths
If you absolutely want a roof material that doesn't meet the cool-roof minimums (e.g., a dark slate-look metal that fails aged SR), Title 24 allows "performance-based" alternative paths:
- Increased attic insulation — adding R-value beyond minimum requirements can offset roof thermal performance shortfalls
- Radiant barrier installation — a reflective foil layer in the attic can compensate for less reflective roofing
- Higher-efficiency HVAC — installing premium-tier HVAC sometimes folds into the compliance calculation
- Solar PV installation — solar panels can offset Title 24 cooling load calculations indirectly
These alternative paths require a Title 24 compliance specialist (HERS rater or similar) to do the calculations. Adds a specialist fee on top of project cost. Usually only worth it if the chosen roof material is significantly cheaper than the cool-roof-compliant alternatives.
What inspectors actually check
- Physical cool roof label on shipped material (during install inspection)
- CRRC certificate in the permit file (plan check)
- Compliance form CF-1R/CF-2R signed by contractor (plan check)
- Sometimes: thermal imaging or reflectance measurement (rare, but cities have authority)
Penalties for non-compliance
If a roof is installed without proper Title 24 compliance documentation:
- Final inspection fails — no Certificate of Occupancy / Final Sign-Off
- You can be required to remove and replace the roof at your cost
- Re-permitting required, with full plan check
- If discovered later (during home sale, insurance audit), the property cannot be sold or refinanced until corrected
In practice, plan check catches most issues before install begins. The risk is biggest with contractors who skip permitting entirely — that's a separate set of problems beyond Title 24.
The 2025 Title 24 cool roof rules in context
California's energy code is updated every 3 years. The 2022 code was effective Jan 1, 2023; the 2025 code (effective Jan 1, 2026) is the seventh major revision since 1978. Each cycle generally tightens performance requirements. The 2025 update specifically:
- Tightened aged SR minimums by 0.05-0.10 in most climate zones
- Reduced the scope of like-for-like alteration exemptions (more reroofs trigger compliance)
- Aligned cool-roof requirements more closely with the State's broader carbon-reduction targets
- Added explicit solar-ready provisions for new construction reroofs (Title 24 Part 6 §150.0(s))
- Strengthened CRRC product certification requirements (third-party verification mandatory)
The 2028 code (effective Jan 1, 2029) is already in development and is expected to tighten further. Homeowners reroofing in 2026 with metal roofs typically exceed the 2025 minimums by enough margin to remain compliant with anticipated 2028 standards as well — meaning you won't be forced to retrofit when the next code cycle takes effect. Title 24 Part 6 cool-roof rules also overlap with fire-code requirements in VHFHSZ areas — homeowners in mapped zones should pair this guide with our overview of Class A fire-resistant roofing options so the chosen product satisfies both code regimes in one pass.
How HVAC equipment changes interact with Title 24
If you're also replacing or upgrading HVAC equipment in conjunction with your roof, the combined work may trigger more comprehensive Title 24 compliance. Common scenarios:
- New AC condenser + reroof: stays within "alteration" scope. Cool roof requirement applies; HVAC efficiency requirement separate.
- Full HVAC system replacement + reroof: may trigger building envelope review. Title 24 compliance specialist (HERS rater) often required.
- Adding solar PV with reroof: triggers solar-ready provisions on remaining roof areas. Common for new construction; less common for existing reroofs.
- Adding heat pump water heater + reroof: rare to combine, but if pursued, falls into broader Title 24 calculation.
Specific products that pass Title 24 in LA Climate Zone 9
For homeowners wanting to verify product compliance before contract signing, these specific manufacturer products consistently meet aged SR + TE requirements for residential reroofs in LA (verify current CRRC listing at coolroofs.org before purchase):
- Metal — standing seam: Englert Series 1300 with Cool PVDF coatings (Slate Gray, Weathered Bronze, Sandstone), McElroy Maxima with PVDF, AEP Span Streamline with cool pigments, PAC-CLAD's PAC-150 in cool color formulations
- Metal — stone-coated steel: DECRA Villa Tile, DECRA Tile in light terracotta, Boral Saxony 900 Cool Tile in approved colors, Westile light-tone tile profiles
- Cool-rated asphalt: GAF Timberline Cool Series, CertainTeed Landmark Solaris, Owens Corning Cool — all with aged SR ≥0.25 (alternative compliance via insulation may still be needed)
- Tile: Eagle Roofing Cool tile lines, Boral concrete cool tile, MCA Catalina Reflective Series
- Avoid for Title 24: bare galvalume, polyester-coated metal, standard SMP coatings without cool pigments, generic asphalt shingles, dark colors without cool-dark pigment technology
The product spec sheet from your contractor should explicitly cite the CRRC product certificate ID. If they can't provide it before contract signing, that's a signal they may struggle through plan check.
Title 24 cool-roof and other utility programs
Some California utilities have historically offered cool-roof related programs tied to Title 24 compliance — terms, eligibility, and availability vary by utility and program year. For current information, check directly with your utility (LADWP, Burbank Water and Power, Glendale Water and Power, Southern California Edison, etc.). The contractor we connect you with will provide the CRRC documentation needed for any program application.
Want a contractor who knows Title 24 cold?
We connect LA homeowners with licensed roofers who handle Title 24 compliance documentation correctly the first time. They submit the right product specs, the CRRC certificate, and the CF-1R form so plan check moves fast.
Official sources: California Energy Commission — Building Energy Efficiency Standards · CRRC product directory.