Solar Roof Tiles and Shingles: Do They Need a Cool Roof Rating?
Only the active photovoltaic area is exempt. When a roof is fully replaced with an integrated solar roofing product, the inactive filler pieces are ordinary roofing: where a cool roof rule applies they need a Cool Roof Rating Council rating, and unrated ones fall back on low defaults. Re-roofing with solar does not itself trigger a PV sizing requirement.
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The manual's own scenario
The single-family manual poses this case: a steep-sloped roof in climate zone 12, fully replaced with an integrated PV roofing product that mixes active PV pieces with visually identical inactive filler pieces. Its answer is that the product must comply with the Energy Code and be rated by the Cool Roof Rating Council, and "only the active photovoltaic area of the roof is exempt."
What a filler piece has to show
A roofing product used to meet or take credit for reflectance and emittance needs a packaging label giving emittance plus initial and aged reflectance, or a CRRC Rapid Rating. An uncertified product is assigned 0.08 aged reflectance and 0.75 emittance if it is an asphalt shingle, or 0.10 and 0.75 for any other roofing. Both sit below the 0.20 aged reflectance a steep roof needs.
Where the exemption is written
New homes: Exception 1 to Section 150.1(c)11 frees building-integrated PV and solar thermal panels from the reflectance, emittance and SRI minimums, and the steep-slope minimum itself applies only in zones 10 to 15. Existing homes: Exception 2 to Section 150.2(b)1Ii and 1Iiia gives the same relief to roof area under such panels.
Re-roof checks that may make the filler moot
On an existing house the rules start only above 50 percent roof replacement, and for steep slopes only in zones 4 and 8 to 15. Roofs weighing at least 25 pounds per square foot are excused, and an R-38 ceiling, a qualifying attic radiant barrier or R-2 continuous deck insulation counts as equivalent.
No PV sizing trigger
Section 150.1(c)14 requires PV on newly constructed single-family homes. Additions are excused by Exception 6 to Section 150.2(a), and the alteration section has no PV item, so a solar re-roof sets no system size.
Give the roofer the zone and the rated filler product, and mark the active PV area on the roof plan. See roof replacement, cool roof re-roof rules, cool roof shingles and adding solar to an existing home. See our residential reports.
Common Title 24 Questions
- When is Title 24 required for a home?
- Does a remodel need Title 24?
- Does a room addition need Title 24?
- What plans are needed for a residential Title 24 report?
- How much does a residential Title 24 report cost?
- How long does a residential Title 24 report take?
Frequently Asked Questions
Where a cool roof rule applies to the roof, yes. The manual says only the active photovoltaic area is exempt, and the product must be CRRC rated.
Not under the Energy Code. The PV requirement applies to newly constructed single-family homes, not to alterations.
Explore Roofs
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- Title 24 Re-Roofing and Cool Roof Requirements
- Do I Need Title 24 for a Roof Replacement?
- Cool Roof Requirements When Reroofing a House
View all Roofs guides → · Windows and Building Envelope · Title 24 guide