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On February 7, 2023, the NAM filed an amicus brief urging the D.C. Circuit to set aside the U.S. Consumer Product Safety Commission’s mandatory rule overriding voluntary industry safety standards for custom widow covering cords that, if implemented, would have a devastating impact on the custom window covering industry. We argue that CPSC issued the mandatory rule in violation of the Administrative Procedure Act because of its failure to clear the high bar required for CSPC to override voluntary standards--here, the agency failed to show that rule was necessary and justifiable and conducted a flawed cost-benefit analysis which failed to account for the impact on small businesses. The CPSC also failed to provide a proper notice and comment period, finalizing a rule that deviated substantially from the initial proposal. In recent years, CPSC has been increasingly aggressive in overriding voluntary standards, pushing its authority beyond the parameters Congress set for it when it enacted the Consumer Protection Safety Act. This case therefore has significant ramifications for the regulatory landscape surrounding consumer products—specifically, whether CPSC will have to defer to voluntary standards or be allowed to overstep its statutory bounds to issue mandatory regulations. Happily, on September 12, 2023, the D.C, Circuit vacated CPSC's final rule.