What the Florida Building Code says about re-covering
For houses, the rule is Section R908.3 of the Florida Building Code, Residential, 8th Edition (2023). New roofing can't go on until every old layer comes off in any of these cases:
- The existing roof is water-soaked or too deteriorated to serve as a base.
- The existing roof is wood shingle or shake, slate, clay, cement or asbestos-cement tile.
- The roof already has two or more layers of any roof covering.
- There are blisters that haven't been cut open and secured.
- The new roof would fasten to the old covering and can't meet the code's securement rules.
One exception matters for metal. A complete, separate system such as standing seam doesn't require removing the old covering. It has to be designed to carry roof loads straight to the structure, without leaning on the old roof.
Notice what's missing, too. The sections numbered for roof re-cover, R908.3.1 and R908.4, read "Reserved" in Florida's text.
So can you put a metal roof over shingles in Florida? Only when none of the five conditions apply, or under that separate-system exception.
Florida's 9th Edition (2026) building code is scheduled to take effect December 31, 2026, according to the Florida Building Commission's workplan. Ask your roofer which edition your permit date falls under.
Florida product approvals decide the details
The City of Orlando's re-roof form asks for a Florida product approval number for each product on the job. It lists "Metal - Direct Attachment" and "Metal with Purlins" as separate roof types.
Approval files show how specific this gets. The state's product approval site, floridabuilding.org, hosts evaluation reports written for metal panels over shingles, such as a 2017 report on a 29-gauge through-fastened panel.
At final inspection, Orlando wants the product approval's installation instructions, or site-specific engineering, on site. The products in the field have to match the application. If a panel's approval doesn't cover going over shingles, ask the roofer how it plans to meet that requirement.
Metal re-roof permits in Orlando and Orange County
Inside city limits, Orlando's residential re-roof application has you check one box: "Replacement" (remove existing and replace) or "Re-cover" (new roof over existing). It also requires two inspections, a dry-in (code 125) and a final (code 600).
The city reinstated the dry-in inspection for all re-roofs on January 1, 2020. Its permit page warns that a roof that skips it may fail final. Part or all of the covering may then have to come off so inspectors can see the underlayment and sheathing nailing.
The final inspection also needs an affidavit verifying the roof deck nail-down and the secondary water barrier.
In unincorporated Orange County, roof permits go through the county's Fast Track system, with "Re-Roof" as a listed work type. The city and the county both require a recorded Notice of Commencement when the work is worth more than $5,000.
The 25% rule and partial roof jobs
Florida Statute 553.844(5) covers partial work. It applies when 25% or more of a roof built to the 2007 Florida Building Code or later is repaired, replaced or re-covered. In that case, only that part must meet the current code.
Local governments can't amend that exception. It rarely decides a full metal roof, since the whole roof is new anyway. It comes up when only one section, like a porch or a back slope, goes to metal.
Why tear-off usually wins in Orlando
Our answer to can you put a metal roof over shingles in Florida is yes, but we'd pick tear-off on most Orlando houses. The code and the permit office make the reasons plain:
- The deck gets seen. Orlando's final affidavit covers deck nailing and the secondary water barrier, and a re-cover hides the deck.
- Older homes get wind upgrades. On wood-deck homes permitted before the Florida Building Code, R908.7 calls for deck re-nailing and a secondary water barrier when the old covering comes off.
- Rot stays hidden under a re-cover. A water-soaked or deteriorated roof can't be covered under R908.3, and nobody can judge that from the ground.
- Some systems need the deck. Metlok's pressed steel shingles, for example, go on synthetic underlayment over a plywood deck. See metal shingles in Orlando.
- Loads add up. R908.2 requires the structure to carry the roof covering plus the materials and equipment used to install it.
The exception for separate systems is real, and it fits standing seam designed to carry loads to the framing. A re-cover can also save tear-off labor and disposal. McElroy Metal says the old layer can make rain noise on a metal roof even quieter.
Checking an over-shingle metal roof quote
Can you put a metal roof over shingles in Florida and come out ahead? Sometimes, if the roofer can answer three questions:
- Which product approval covers metal over shingles for this panel?
- How will the deck condition be checked before it's covered?
- Which box goes on the permit: Replacement or Re-cover?
Then compare that bid with a tear-off bid. Our metal roof cost guide for Orlando covers local pricing. The list of metal roofers in Orlando gives you a second installer to ask.
Sources: Florida Building Code, Residential, 8th Edition (2023), Chapter 9, Sections R905 and R908 (ICC); Florida Statutes 553.844 (2025); Florida Building Commission, 9th Edition (2026) workplan, October 2026; floridabuilding.org, product evaluation report FL17617 (Imperial Rib over shingles, 2017); City of Orlando, Apply for a Residential Roof Permit; City of Orlando, Residential Re-Roof Application; Orange County, Roof Permit; McElroy Metal, Are Metal Roofs Noisy When it Rains or Hails?; Metlok.
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