Time is quickly running out for companies to file documentation proving the minerals in their supply chain that may have originated in the Democratic Republic of the Congo region of Africa are in fact conflict-free, as mandated by Section 1502 of the Dodd-Frank Act. As the June 2 deadline approaches, the D.C. Circuit Court of Appeals has called into question the legality of parts of the rule.
On April 14, the court struck down part of the rule on First Amendment grounds [PDF], but the potential fallout of that decision is unclear. Even with the rule continuing as planned for now, it appears that many companies are behind in the compliance process.
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