CPSC, SEC/CFTC, and NRC Issue Three Regulatory Actions on Battery Safety, Fund Reporting, and Spent Fuel Storage

Button Cell Battery Standard: CPSC Seeks Public Comment

The U.S. Consumer Product Safety Commission is soliciting public comment on a revised voluntary standard for products containing button cell or coin batteries, with comments due by September 17, 2026. The CPSC's mandatory rule, codified at 16 CFR part 1263, incorporates by reference ANSI/UL 4200A — the Standard for Safety for Products Incorporating Button Batteries or Coin Cell Batteries — and UL has now notified the Commission that it has approved and published a revised version, designated UL 4200A-2026.

The mandatory standard was originally issued under Reese's Law, which the document states was enacted to protect children six years old and younger against hazards associated with the ingestion of button cell or coin batteries during reasonably foreseeable use or misuse conditions. The law broadly defines a button cell or coin battery as either a single cell battery with a diameter greater than the height of the battery, or any other battery that the Commission determines poses an ingestion hazard. The mandatory standard at 16 CFR part 1263 includes performance requirements and test procedures, as well as requirements for warning labels and instructions, to address the ingestion hazard.

Section 2(f) of Reese's Law sets a strict statutory process for revisions: once UL notifies the Commission of a change, the Commission has 90 days to reject the revised standard in whole or in part by notifying the voluntary standards organization that the revision does not improve safety. If the Commission does not act within that window, the revised standard is automatically considered a consumer product safety standard issued under section 9 of the Consumer Product Safety Act, effective 180 days after the Commission received notification of the revision (or a later date the Commission specifies in the Federal Register). Because of this short statutory time frame, the CPSC states it will not consider comments received after September 17, 2026. A read-only copy of UL 4200A-2026 is available at no cost on UL's website, and interested parties may also schedule an appointment to inspect a copy at CPSC's Office of the Secretary in Bethesda, Maryland.

Form PF Compliance Date Extended Again to July 1, 2027

The CFTC and SEC have jointly extended the compliance date for their 2024 amendments to Form PF — the confidential reporting form for certain SEC-registered investment advisers to private funds — from October 1, 2026, to July 1, 2027. The joint final rule extending the date took effect September 3, 2026.

Form PF was established under Sections 404 and 406 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, which require that private fund advisers file reports and specify certain types of information subject to reporting and recordkeeping requirements. The Dodd-Frank Act authorizes the SEC to require that private fund advisers file information as necessary and appropriate in the public interest and for the protection of investors, or for the assessment of systemic risk. The form covers SEC-registered investment advisers, including those also registered with the CFTC as a commodity pool operator or a commodity trading adviser.

The 2024 Form PF Amendments were adopted on February 8, 2024, and the Commissions initially established a compliance date of March 12, 2025. The Commissions extended that date to June 12, 2025, to address challenges associated with the timing of reporting cycles for Form PF. Significant challenges remaining led to a further extension to October 1, 2025, and then again to October 1, 2026. The current extension to July 1, 2027, reflects the Commissions' stated intent to allow more time to complete a substantive review of Form PF. The affected regulation is 17 CFR 279 (specifically 17 CFR 279.9).

NRC Confirms Effective Date for Holtec HI-STORM Spent Fuel Cask Amendment

The Nuclear Regulatory Commission has confirmed that a direct final rule amending its list of approved spent fuel storage casks will take effect as scheduled on October 6, 2026. The rule, originally published in the Federal Register on July 23, 2026, adds Amendment No. 10 to Certificate of Compliance No. 1032 for the Holtec International HI-STORM Flood/Wind System, amending NRC regulations in 10 CFR part 72.

When the direct final rule was published, the NRC stated that it would become effective on October 6, 2026, provided no significant adverse comments were received. The NRC received and docketed three comment submissions on the companion proposed rule. After evaluating those comments against the criteria described in the direct final rule, the NRC determined that the comments were not significant and adverse, and therefore confirmed the rule will proceed on its original schedule.

What to Watch

• September 17, 2026 — Deadline for public comments to CPSC on whether revised voluntary standard UL 4200A-2026 improves the safety of products containing button cell or coin batteries; comments received after this date will not be considered.
• October 1, 2026 — Previous (now superseded) Form PF compliance date for the 2024 amendments.
• October 6, 2026 — NRC direct final rule adding Amendment No. 10 to Certificate of Compliance No. 1032 for the Holtec HI-STORM Flood/Wind System takes effect.
• July 1, 2027 — New compliance date for the 2024 Form PF Amendments for all filers and large hedge fund advisers.

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