The Roofing Book

Permitting Authorities / Memphis and Shelby County Office of Construction Code Enforcement (Division of Planning and Development)

Memphis and Shelby County Office of Construction Code Enforcement (Division of Planning and Development)

Adopted code

The consolidated construction-code enforcement authority for the City of Memphis and unincorporated Shelby County (also covering several satellite Shelby County municipalities). It publishes a dedicated "Policy for Roof Installations" document, revised June 8, 2022, which sets out the county's re-roofing rules in plain Q&A form and is the controlling local statement on permits, decking, drip edge and ice barrier for roofing work. Memphis is in Shelby County. Construction-code enforcement for the City of Memphis is performed jointly with Shelby County by this consolidated office (branded develop901.com). Tennessee's State Residential Building Code Enforcement Program under T.C.A. 68-120-101 applies only in areas that have not received an exemption from the State Fire Marshal's Office by enforcing local building codes, and have not opted out by two-thirds vote of the local legislative body. Memphis/Shelby County falls in the first category: it enforces its own locally adopted codes, so it is exempt from state enforcement and applies its OWN adopted IRC edition (2021 IRC with local amendments), NOT the state's 2018 IRC baseline. Tennessee does not preempt local amendment of the residential code, so no state-level roof-covering provision may be assumed to apply here -- every roofing field in this record is sourced to the local Memphis/Shelby instrument rather than to state law.

Jurisdiction
City of Memphis, Shelby County, Tennessee
Jurisdiction type
city
Contact
  • url: https://www.develop901.com/construction-enforcement
Roofing permit required
Not required
Contractor registration required
Required
Registration details
  • license: STATE licence, not a city registration. The Shelby County office states it directly: "Is a Tennessee Licensed Contactor required for roofing in Shelby County? Yes, when a project is over $3,000, depending on monetary limit, either a Home Improvement Contractor or a Building Contractor licenses is required." (The office's own document has these two typos -- "Contactor" and "licenses" -- reproduced here as printed.) The "depending on monetary limit" split is Tennessee's two-tier regime under T.C.A. Title 62, Chapter 6, administered by the Tennessee Board for Licensing Contractors: (1) roofing work from $3,000 up to but not including $25,000 on a residence requires a Home Improvement License, a separate licence track under T.C.A. 62-6-501 et seq. that applies in only nine Tennessee counties -- Bradley, Davidson, Hamilton, Haywood, Knox, Marion, Robertson, Rutherford and SHELBY -- so it does reach Memphis; and (2) work at or above $25,000 total cost, materials and labour, requires the full BLC Contractor's Licence, which carries a monetary limit and a classification, roofing being licensed as a specialty under the Building classification rather than as a freestanding roofing licence. Jobs at or under $3,000 trigger neither state licence. No additional City of Memphis or Shelby County contractor registration on top of the state licence was identified. The two-tier state licensing regime is corroborated for Shelby County by the local office's own policy document.
Adopted code
The office's Policy for Roof Installations (rev. June 8, 2022) states: "We have adopted the 2021 version of the IRC along with local amendments." Confirmed again in Q&A form: "What edition of the IRC do you enforce? The 2021 edition of the International Residential Code." Per the same policy, "The only part of chapter 9 [Roof Assemblies] that we amended was the requirement for an ice and water shield. Other than that, we enforce the entire chapter" of the 2021 IRC.
Drip edge
Required — The office's Policy for Roof Installations answers in Q&A form: "Does Shelby County require a drip edge? Yes, per chapter 9 of the 2021 IRC." Also stated in narrative form: "we are asked if we enforce the installation of a drip edge per section R905.2.8.5 ... The answer is yes."
Ice & water shield
Not required — The office's Policy for Roof Installations answers in Q&A form: "Does Shelby County require an ice and water shield (barrier)? No, per our local amendment." Confirmed again: "there are no amendments to chapter 9 of this code other than we do not require an ice barrier per section 905.1.2." This is a LOCAL AMENDMENT removing the 2021 IRC's default ice-barrier requirement -- consistent with Memphis's climate (ice-dam formation is not a design concern there).
Mid-roof inspection
Not required — No mid-roof or in-progress roofing inspection is described anywhere in the office's own Policy for Roof Installations document. Because the same policy requires no permit at all for a plain reroof that does not involve deck work, there is no inspection trigger in the ordinary re-roofing case -- the policy itself acknowledges that for such jobs "we may never see the work that was done." Where deck work does pull a permit, contact the office for the inspection sequence that applies; the roof-installations policy does not set one out.
Impact-resistant roofing
Not required — No impact-resistance requirement applies. Shelby County/Memphis enforces the 2021 IRC, and the office's own Policy for Roof Installations states the complete scope of its roof-chapter amendments: "The only part of chapter 9 [Roof Assemblies] that we amended was the requirement for an ice and water shield. Other than that, we enforce the entire chapter," restated as "there are no amendments to chapter 9 of this code other than we do not require an ice barrier per section 905.1.2." The 2021 IRC roof-assemblies chapter contains no UL 2218 / Class 4 impact-rating mandate, and the county has added none. Nothing in the policy document references UL 2218, Class 4, impact rating, or hail resistance. Note that IRC roof "Class A/B/C" classifications, which do apply here, are ASTM E108 / UL 790 FIRE ratings and are not impact ratings.
Repair permit threshold
Policy for Roof Installations (rev. June 8, 2022), in Q&A form: "Is a permit required for a reroof job on a single family home? No, a permit is not required unless the decking is to be repaired or altered." Also: "A permit is not required for a residential roof repair unless decking is damaged." So a straight re-roof/recover or like-for-like shingle repair on a single-family home needs NO permit; the trigger for needing a permit is specifically deck work ("New sheathing or repair to sheathing does require a permit"). The no-permit-for-roofing-alone rule is a deliberate published policy of this office, not a gap in its guidance. It is written for single-family homes; the document does not address multifamily or commercial structures, so confirm those with the office directly.
Wind design criteria
Per Table R301.2(1), Climatic and Geographic Design Criteria, as amended by Joint Ordinance No. 569 (further amending the 2021 IRC local amendments for the City of Memphis and unincorporated Shelby County, effective April 1, 2025): the ultimate design wind speed is 105 mph. Topographic wind effects, the special wind region designation, and the windborne debris zone designation are all marked "No" in the table, so Memphis and Shelby County carry none of those special wind provisions. The same table shows a 10 psf ground snow load and Seismic Design Category D1, and confirms no ice barrier underlayment is required, consistent with the local amendment described elsewhere in this record. The table does not assign a single jurisdiction-wide exposure category; under the unamended IRC, exposure category is determined site-by-site.
Roof layer limit / recover
No fixed numeric layer limit is enforced as policy. Q&A: "How many layers of roof can I have on my house before I am required to remove existing layers? This depends entirely on-site specific circumstances and the materials used. For additional direction, please see IRC 2021 Section 1512.2.1." Note on that citation: the policy document's own cross-reference reads "1512.2.1," which does not match the 2021 IRC roof-covering numbering (chapter 9, R9xx series) the same document uses everywhere else, and appears to be a typographical error in the source PDF for an R905-series recover/replacement section. It is reproduced here as printed rather than silently corrected. The practical effect is that a roofer must get a layer-count determination from the office for the specific property; there is no published "two layers maximum" style rule to rely on.
Deck & sheathing requirements
The office's Policy for Roof Installations states: "We will allow an average of 1/4" gaps on existing roofing before requiring the deck to be overlaid. If the gaps exceed an average of 1/4", some means of repair must happen by either filling the gaps or overlay 3/8" wood structural panel sheathing per Table R503.2.1.1(1). Additionally, overlaying existing decking with 3/8" or thicker sheathing adds substantial weight to the existing rafters and will require a letter from a structural engineer approving the new load on the existing structure. New sheathing or repair to sheathing does require a permit." Underlayment is separately required: "Is underlayment required for my new roof installation? Yes, per Table 905.1.1(2) of the IRC."
Sales & use tax
9.75% combined on retail sales sourced to the City of Memphis, broken down as 7.00% Tennessee state rate + 2.25% Shelby County local rate + 0.50% City of Memphis local rate (city rate effective since January 1, 2020). The rest of Shelby County that has not levied a city increment sits at the county floor of 9.25% (7.00% state + 2.25% county), so the rate carried by a roofing materials purchase depends on whether the delivery point is inside the Memphis city limits. Confirmed directly against the Tennessee Department of Revenue's own local sales tax rate and boundary file: Shelby County (county code 157) carries a 2.25% local rate, and the Memphis place-code row carries a 2.75% local rate (7.00% state + 2.25% Shelby County + 0.50% Memphis city increment = 9.75%).

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