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Building Code Reference

Got a Title 24 110.8(i) correction?

Cool roof requirements

For builders in California, Greater Seattle, the Las Vegas area, the Denver area and Kansas City · CrossBeam Permits

What this code requires, how to fix it, and how cities and counties review it

What this code requires

Title 24 Section 110.8(i) is the California Energy Code provision that requires a roofing product's aged solar reflectance and thermal emittance to be certified and labeled (through the Cool Roof Rating Council) whenever it is used to meet the cool roof rules, and it sets default values for uncertified products. The minimums themselves are in the prescriptive sections: 150.1(c)11 for single-family homes, 140.3(a)1A for nonresidential buildings, and 170.2 for multifamily. Each slope category and climate zone has its own threshold, or an equivalent Solar Reflectance Index (SRI). Residential reroofs that replace more than 50 percent of the roof also fall under these rules.

How to fix it

  1. Identify your climate zone and roof slope category

    Find the project’s climate zone from the CF1R energy compliance form or from the climate zone map published by the California Energy Commission at energy.ca.gov. Then measure the actual roof pitch: less than 2:12 is low-sloped, 2:12 or greater is steep-sloped. Title 24 sets separate aged solar reflectance and thermal emittance thresholds for each category (150.1(c)11 for single-family, 140.3(a)1A for nonresidential), and the thresholds further vary by climate zone. Getting both inputs right before selecting a product prevents the most common resubmit cycle on cool roof corrections.

  2. Find a CRRC-listed product with passing aged performance values

    The Cool Roof Rating Council (CRRC) maintains the rated products directory. Search by manufacturer and product name. Each listing shows both initial and aged solar reflectance plus aged thermal emittance. The aged values are what the code enforces — initial values alone are not sufficient. If your current product is not listed, or its aged reflectance falls below the required threshold for your slope category and climate zone, select a different product. You can also check the Solar Reflectance Index (SRI) as an alternate compliance path if the product has a combined SRI rating that meets the minimum.

  3. Update the roof spec on the plans with the CRRC ID and performance values

    On the roof plan or general notes sheet, update the cool roof specification to include: (1) the CRRC product ID number, (2) the product’s listed aged solar reflectance value, (3) the product’s listed aged thermal emittance value, and (4) the applicable climate zone. A note that reads “cool roof per Title 24 110.8(i)” without any of this detail will get flagged again. A note like “CRRC Product ID XXXX-XXXX, aged reflectance 0.XX, aged emittance 0.XX, steep-sloped, Climate Zone XX” gives the plan-checker everything they need to clear it. For example, a single-family steep-sloped roof in Climate Zone 10 needs at least 0.20 aged reflectance and 0.75 emittance, or SRI 16.

  4. Regenerate the CF1R to match the updated roof product values

    The CF1R (CF1R-NCB-01-E for a prescriptive newly constructed single-family home) has an input field for roof solar reflectance. That value must match what you’ve spec’d on the plans. If the CF1R was generated with the default for an uncertified product (aged reflectance 0.10, or 0.08 for asphalt shingles) but the plans now show a CRRC-rated product with a higher aged reflectance, regenerate the CF1R with the correct input and resubmit both documents together. Plan-checkers compare these two documents side by side — a mismatch triggers a correction even when the product itself would otherwise pass.

  5. Check for local amendments stricter than state minimums

    Some California cities have adopted cool roof ordinances that go beyond state minimums. Los Angeles has required higher reflectance thresholds on low-sloped commercial roofs under local ordinances. Check your city’s adopted amendments before finalizing the product selection — a product that clears the Title 24 state minimum may still fail a local amendment check. For Orange County jurisdictions, review the adopted local ordinances on the city’s building department portal before your next submittal.

  6. Check whether an exception applies and document it explicitly

    The cool roof rules have exceptions worth reviewing before you assume full compliance is required. For single-family homes, building integrated photovoltaic and building integrated solar thermal panels are exempt, and so are roof constructions weighing at least 25 lb/ft². Standard rack-mounted PV is not listed. Nonresidential roofs have their own exceptions in 140.3, including an insulation tradeoff. If an exemption applies to your project, the plans must include a specific note citing the section of the code that grants the exemption and the factual basis for it. A bare “exempt” notation without that backup will not pass.

  7. Reference the CF2R installation certificate requirement on the plans

    For residential projects, the cool roof installation must be documented on a CF2R installation compliance certificate completed by the licensed contractor after installation is done. The CF2R records the actual product installed and its CRRC ID, confirming that what went on the roof matches what was approved. At plan check, the reviewer expects the plans to note that a CF2R will be completed for the cool roof installation — it doesn’t need to be in the plan set itself, but the reference needs to be there. This requirement is frequently a follow-up correction after the reflectance spec issue is resolved.

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Why you got flagged

Here’s why plan-checkers flag 110.8(i): most contractors include a roofing spec on the plans without linking it to a listed product that has verified aged performance data. The plan-checker opens the CRRC rated products directory, searches for the product you listed, and finds either no listing at all or a listing that shows the product doesn’t hit the aged solar reflectance threshold for your climate zone. That’s the correction — a generic “cool roof per Title 24” note without a CRRC product ID and actual aged performance numbers is never going to pass plan check.

The second common scenario is a slope category mismatch. Title 24 differentiates between low-sloped roofs (less than 2:12 pitch) and steep-sloped roofs (2:12 and above), with separate performance thresholds for each. A project spec’ing a cool roof product tested on a low-slope assembly gets flagged when the actual roof pitch is 5:12 — the tested values may not apply, and the note on the plans doesn’t clarify which slope category the product is listed under.

Climate zone errors are the third trigger. California has 16 climate zones, and the required aged reflectance levels are not the same across all of them. Many contractors copy a cool roof note from a previous project in a different climate zone without updating the performance spec. A project in Climate Zone 10 (inland Southern California) can require higher aged reflectance than one in Climate Zone 1 (far northern CA). When the energy compliance form (CF1R) and the roof spec don’t agree on the climate zone inputs, 110.8(i) gets flagged — and fixing just one document without updating the other only creates a second correction round.

The official code

California Energy Commission: 2025 Building Energy Efficiency Standards (Title 24, Part 6)

Read the source →

Common questions

Does Title 24 110.8(i) apply to reroofing, or just new construction?
It applies to both. When you’re replacing more than 50 percent of the roof covering on an existing home, the replacement must comply with the cool roof requirements for your building type and climate zone; for nonresidential and hotel/motel roofs the trigger is more than 50 percent or more than 2,000 square feet, whichever is less. Smaller partial reroofs may not trigger the requirement — but confirm this with your local building department because some jurisdictions have adopted stricter thresholds for when compliance kicks in. Document the total roof area and the area being replaced in your plans so the plan-checker can verify which side of the threshold you’re on.
What’s the minimum aged solar reflectance for a low-sloped roof under 110.8(i)?
The specific thresholds vary by climate zone and building type. Pull the exact values from the 2025 Building Energy Efficiency Standards tables at energy.ca.gov for your specific climate zone and whether the project is residential or nonresidential. The variation across zones is significant enough that using a generic threshold from a different project is a common reason for corrections.
Can I use the Solar Reflectance Index (SRI) instead of separate reflectance and emittance values?
Yes. Title 24 110.8(i) allows an SRI compliance pathway as an alternative to meeting both the aged solar reflectance and aged thermal emittance thresholds separately. SRI is a single composite number that accounts for both properties. If your product’s SRI meets the minimum for your roof slope category and climate zone, the product can comply even if one of the individual values on its own might not clear the threshold. List the SRI value from the CRRC product listing and the applicable minimum SRI on your plans, the same way you would for the two-value compliance path.
My rooftop solar panels cover most of the low-sloped area. Do I still need a cool roof?
Probably yes. The single-family exception covers building integrated photovoltaic panels and building integrated solar thermal panels; standard rack-mounted panels over the roof are not listed, so the roofing beneath and around them still needs a compliant product. Roof constructions of at least 25 lb/ft² are also exempt. On your plans, show any building integrated panel area separately, then spec a compliant cool roof product for the rest of the roof. Make the area calculation visible; plan-checkers won’t assume the exemption without seeing the math.
What’s the difference between initial solar reflectance and aged solar reflectance?
Initial reflectance is measured when the product comes off the production line. Aged reflectance is measured after three years of outdoor exposure. Roof surfaces degrade in reflectance over time as dust, biological growth, and UV weathering change the surface. Title 24 enforces the aged value because that’s what the roof delivers over its working life, not just on install day. A product can have a high initial reflectance but drop significantly at three years and fail the code requirement. Always pull both values from the CRRC listing and verify the aged number clears your climate zone’s threshold before putting it in the spec.
Does 110.8(i) apply to steep-sloped roofs like asphalt shingles on a 5:12 pitch?
Yes, but the thresholds are lower than for low-sloped roofs. Steep-sloped assemblies (2:12 pitch and above) receive less direct solar load at high sun angles, so the minimum aged reflectance requirements are reduced in most climate zones. In some zones and for some building types, steep-sloped roofs face no cool roof requirement at all. Check the 2025 Energy Code tables at energy.ca.gov for your specific combination of zone and slope. If requirements do apply, many CRRC-listed asphalt shingle products clear the steep-slope thresholds — just verify the aged reflectance value from the listing matches what you need.

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