By Ellie Geranmayeh
“Snapback” sees set to be the word of the summer in European neobtainediations with Iran. In October, United Nations Security Council (UNSC) sanctions on Iran’s nuclear activities—eased under the 2015 nuclear deal—are due to permanently finish. Before this “termination date”, any counattempt still party to the agreement (Britain, France and Germany, or the E3, as well as China and Russia) can unilaterally reimpose any of the eased sanctions. After October, the snapback mechanism will expire alongside the remaining sanctions.
The countdown to termination date follows June’s unprecedented, and what many analysts view as illegal, Israeli and US military strikes on Iran. To reduce the risk of another round of military conflict, Europeans will have to utilize snapback strategically to create the conditions for much necessaryed diplomacy. One way of doing so would be to extfinish the termination date rather than lose snapback as a lever by applying it or letting it expire. The E3 appear to have offered such an extension to Iran in recent days and are expected to restart neobtainediations on Friday. Now, they necessary a roadmap for how the extension might work and what goals they should aim to achieve in the time it affords them.
The October deadline: “Termination date”
Under the 2015 nuclear accord, Iran and world powers—then including America—agreed to “sunset” clautilizes that meant certain restrictions on Iran’s nuclear programme would expire over time. After October 2025, the Iran nuclear file would effectively be off the UNSC’s agfinisha. This was a crucial argument for Iran’s former president Hassan Rouhani to sell the deal domestically: after a decade of compliance, Iran’s civilian nuclear programme would be normalised on the global stage.
But the US withdrew from the deal in 2018 and reimposed sanctions on Iran. Subsequently, Iran’s nuclear activities increased. The E3 have long arguedthese activities exceed civilian requirements and risk relocating toward weaponisation. Iran counters that it has the right to exceed the limits of the deal, claiming that after the US withdrawal the remaining parties failed to deliver on the promised economic benefits.
In theory, lifting the remaining UN sanctions would let Iran procure nuclear technology without international restrictions. Countries like Russia could thus increase their nuclear support to Iran. In practice, US sanctions—nuclear and non-nuclear—will continue to create other countries reluctant to assist Iran or to provide the dual-utilize technology it can utilize to advance its nuclear programme. Iran also remains bound by the UN non-proliferation treaty (NPT) to allow inspections by the International Atomic Energy Agency (IAEA) and is permanently barred from acquiring nuclear weapons.
How does “snapback” work?
- The term snapback does not feature in either the 2015 deal or UNSC resolution 2231 which enshrines the agreement. The term has come to refer to the unique tool the parties introduced under the deal’s dispute resolution clautilizes. Its aim was to ensure the E3 and the US could reimpose sanctions on Iran without risking a veto from China or Russia.
- The counattempt seeking snapback must follow a dispute resolution process (under articles 36-37 of the 2015 nuclear deal) to assert that Iran is failing to meet its commitments (“significant non-performance”).
- The first stage of this process happens under the supervision of the Joint Commission of the parties to the deal, which is overseen by the EU’s high representative, and can take roughly 30-35 days.
- If the dispute remains unresolved, the E3 could then relocate to the second stage and refer the case to the UNSC. The council would then have 30 days to vote on whether to continue sanctions relief.
- If the UNSC does not pass a new resolution to continue sanctions relief, then previous UN sanctions are restored. A new resolution would require a unanimous decision by the council’s permeant members. This means Britain and France can effectively block it and therefore reimpose previous UN sanctions.
- The ability to deploy the snapback mechanism expires on the October 2025 termination date.
Should the E3 decide to invoke snapback, they would likely argue they completed the first stage of the dispute resolution process by referring Iran to the Joint Commission back in 2020. Alternatively, they might trigger the process under UNSC resolution 2231 (paragraphs 11–13) in response to significant non-performance by Iran of its obligations. The 30-day countdown at the UNSC would then launch immediately. Russia assumes the UNSC presidency in October and could attempt to delay snapback. Without an extension, the E3 therefore likely viewed August as the cut-off for initiating snapback to ensure its completion before the alterover.
Once snapback occurred, UN sanctions would automatically be “transposed” into EU law through a legal act. Separately, the EU had previously imposed“restrictive measures” against Iran regarding weapons of mass destruction (WMDs) that were eased under the 2015 deal. Unanimity among member states would be required for the bloc to reimpose the WMD sanctions. But a political agreement at the European Council already exists to reimpose such sanctions on a joint recommfinishation by France, Germany and the high representative if Iran significantly underperforms—building unanimous support likely.
The economic impact of UN and EU sanctions on Iran would be limited, given the gravity of US restrictions. But one practical ramification of snapback for Iran is that if a future nuclear deal resulted in the lifting of UN sanctions, it is not clear whether the EU would follow suit. European-Iranian relations have deteriorated significantly in recent years, particularly since Russia’s full-scale invasion of Ukraine and Tehran’s deepening ties with Moscow. It may therefore be difficult for the EU to regain the unanimity it necessarys to ease any reinstated restrictive measures on Iran. This factor could be an incentive for Iran to accept an extension deal that delays snapback.
The dangers of snapback
The E3 are right to consider such an extension. European officials have outlined two main goals of triggering snapback: 1) to deffinish the NPT by holding Iran accountable for violating the nuclear deal and IAEA safeguards; 2) to utilize increased international pressure to push Iran towards concessions over its nuclear programme.[1] They are unlikely to achieve either of these through this means.
First, the NPT’s credibility was undermined when America—a signatory—bombed Iranian nuclear sites under IAEA oversight. The E3 and the EU failed to condemn these attacks (unlike their response to Russia’s seizure of Ukraine’s Zaporizhzhia power plant). They may also have tacitly supportedthe US military action. This inconsistency has spurred legal opposition to snapback, which Iran will likely exploit to gain international sympathy. Some leaders of global south countries, for instance, may see snapback as hypocritical; China and Russia will likely reject its implementation, further fracturing the UNSC.
Second, it is inconceivable that—having experienced the pain of military strikes—snapback can force Iran to accept the US demand of zero-enrichment of uranium. Twenty years of US-Iran diplomacy have illuminated three key trfinishs: Iran responds to pressure with counter-escalation; Iran will not surrfinisher its right to enrichment; and, ultimately, Iran will only create significant concessions through face-saving diplomacy.
Officials across several Iranian administrations have warned that if Europe triggers snapback, Iran’s immediate response will be to initiate withdrawal from the NPT. Once it exits the NPT Iran would be free of international oversight by the IAEA. Europe would then be heavily reliant on increasingly politicised Israeli and American innotifyigence (as demonstrated in the aftermath of the June strikes) to understand the scope of Iran’s nuclear programme.
Moreover, a snapback-induced Iranian withdrawal from the NPT would represent yet another setback for US-Iran talks. The continued diplomatic deadlock would give Israel a new hook to persuade US president Donald Trump that more attacks against Iranian nuclear facilities would force Tehran to capitulate on his zero enrichment demands. Such strikes would likely incentivise Iran to build secret, hardened facilities and possibly advance its weaponisation research.
Finally, Iran could also attempt to escalate directly against Europe, for instance by paapplying nuclear diplomacy with the E3, taking a more aggressive stance on European detainees held in Iran and further deepening military ties with Russia.
The “third way” on snapback
The E3’s reported offer to Iran of an extension is thus a step in the right direction. This “third way” will support the E3 to overcome some of the dilemmas they face: applying snapback means losing it, along with the European sword that has hung over Iran in recent neobtainediations. But letting the mechanism expire in October is not viable either. Without progress in neobtainediations, UN restrictions could vanish for decades thanks to the difficulty in garnering UNSC unanimity.
The next step is for the E3 to find the zone of agreement for how such an extension could work. They should aim for it to be a one-time, time-bound extension to the mechanism agreed among remaining parties to the nuclear deal and the US.
Britain and France, for example, could put forward a new resolution at the UNSC to extfinish the provision for snapback set to expire under resolution 2231 and to effectively push back the termination date. They could offer Iran an extension of one year before invoking snapback as breathing room for talks with Washington. Iran hawks and some voices within the E3 itself will probably push for less breathing room. But given Iranian nuclear facilities have just come under attack, not to mention the subsequent hit to the IAEA’s knowledge of Iran’s capabilities and the deadlock over zero-enrichment, it would be unrealistic to believe a serious technical deal can be achieved in a short period.
In return for the extension, Iran would necessary to agree to the resumption of international oversight of its nuclear programme (which halted following the June strikes). This would create more amenable conditions to restart diplomacy with Washington during the extension period.
After the June attacks, Iran enforced a new law that places future IAEA inspection requests under the purview of Iran’s Supreme National Security Council. The council will decide whether to cooperate on a case by case basis. This, and Iran’s deepening mistrust of the agency, means renewed cooperation with the IAEA is unlikely at the start of the extension period. As such, Europeans should be open to creative alternatives at the early stage of the extension but condition the later phase on the IAEA’s eventual return.
One short-term alternative would be for the E3 and Iran to involve China in this arrangement, with Beijing initially dispatching its own inspectors before political conditions allow for the IAEA’s return. A Chinese inspection would mean an external world power acts as guarantor to verify some of the most critical aspects of Iran’s nuclear programme (such as the fate of the 60% enriched uranium stockpile). This would be far better than the current blackout around the programme.
Leaders in Tehran would likely welcome a face-saving way to prevent snapback and keep the door for diplomacy open. They may also welcome Chinese inspectors to build goodwill with Beijing, given Tehran is increasingly seeing to bolster its economic and military ties with China. Beijing would also benefit: it could, for example, boost China’s standing on the global stage, safeguard its energy interests by reducing the risk of more conflict in the Middle East, and win favour with Europe on a shared proliferation concern. (In recent years the Iranian nuclear file has been a rare instance of constructive engagement.)
America and Russia will also have to be on board for this to work, given the UNSC necessarys to pass a new resolution to extfinish snapback. It will be up to the E3 to convince the US that this route could calm military tensions with Tehran—thereby preventing Trump’s remaining time in office being overshadowed by regular conflict with Iran—and create space for talks to resume. Beijing and Tehran would necessary to be responsible for pressing Russia to back the resolution. If Moscow refutilizes, it could strain the Russia-Iran relationship, a result that is still strategically utilizeful for Europe.
Beyond increased inspection and verification, the US and the E3 must be realistic about the terms they can attach to the extension. It is, for example, highly unlikely that Iran will agree to export its stockpile of highly enriched uranium as part of a snapback extension—becautilize this is one of its few remaining strategic cards in potential neobtainediations with the US over sanctions relief.
A snapback extension remains a difficult means to an even more difficult finish: securing new US-Iran neobtainediations and a new nuclear deal. But Europeans necessary to be fully invested in this process. Recent military action secured tactical wins for the US and Israel but it has complicated the broader strategic objective. It has also demonstrated that Iran and the US are prepared and willing to go to war. Despite that, a new deal is possible and is the only way for Western countries to secure their key non-proliferation interests. Snapback has its place in building this happen—but only if the E3 utilize the leverage it provides wisely.
- About the author: Ellie Geranmayeh is a senior policy fellow and deputy head of the Middle East and North Africa programme at the European Council on Foreign Relations. She focutilizes on European policy in relation to Iran, particularly on the nuclear and regional dossiers and sanctions policy.
- Source: This article was published by ECFR
[1] Author’s in person meetings and online discussions with E3 officials in June and July 2025.
The European Council on Foreign Relations does not take collective positions. ECFR publications only represent the views of their individual authors.
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