The E3—France, Germany, and Britain—on Thursday triggered the 2015 Iran nuclear deal’s “snapback” mechanism, initiating a 30-day countdown to the automatic reinstatement of United Nations Security Council sanctions on Iran.
The move was immediately met with strong approval from Washington. Secretary of State Marco Rubio stated, “The E3… initiated a process to reimpose UN sanctions on Iran. Snapback sanctions are a direct response to Iran’s continuing defiance of its nuclear commitments. The United States supports the E3’s decision and urges Iran to engage in serious diplomatic negotiations.” French Foreign Minister Jean-Noel Barrot likewise insisted the move does not spell the “end of diplomacy,” but is rather a bid to force dialogue.
That is a dangerous fantasy. The very premise of the E3’s action—that Iran is the sole violator of the deal—is a profound distortion of history. It was the United States that first withdrew from the deal in 2018, inflicting severe economic damage on Iran through a “maximum pressure” campaign instituted under the Trump administration. At the time, the E3 issued political declarations in support of the agreement but failed to back them with actions that honored their own obligations. Instead, they de facto fell in line with Washington’s extraterritorial sanctions against Iran.
In the face of this European failure, Tehran took actions of its own. As Iranian international law expert Reza Nasri noted on X, “Iran acted under Article 36 of the JCPOA, lawfully reducing its commitments as remedial steps to press the other parties to meet theirs.” Now, he argues, European countries “have the audacity to present Iran’s lawful reaction as clear violations in a cynical ploy to justify the reinstatement of Security Council sanctions”—a move that enjoys full American endorsement.
Russia, another JCPOA signatory, similarly believes the E3 has forfeited the legal right to invoke snapback. A senior Russian diplomat deeply knowledgeable about the issue told The American Conservative that Moscow views some European actions as unilateral violations of the agreement, such as the EU’s extension, in October 2023, of an arms embargo against Iran that had been set to expire. Such acts, the diplomat argued, contravene the terms of both the JCPOA and UN Security Council Resolution 2231, which codified it into international law. This criticism reflects a perception of profound hypocrisy and illegality at the heart of the European move.
Of course, this is only the latest Western action against Iran that raises tensions and undermines international law. The U.S.–Israeli strikes on Iran during the 12-day war in June shattered the last vestiges of trust, leading Tehran to expel IAEA inspectors. It is precisely this tinderbox of provocation and reaction that Europe has now chosen to escalate with its snapback ultimatum. This week’s move was hardly surprising, however. The E3/EU, after all, blamed Iran for Israeli attacks on its territory. German Chancellor Friedrich Merz even praised Israel for doing the West’s “dirty work”—that is, bombing Iran.
Even if Tehran sees the Europeans’ gambit for what it is—an unwarranted escalation of tensions—its response is likely to be measured, at least initially. As Iran analyst Rouzbeh Parsi of Sweden’s Lund University notes, Tehran has significantly toned down its rhetoric regarding the repercussions of a potential snapback. Whereas earlier it had threatened a withdrawal from the Nuclear Non-Proliferation Treaty (NPT), Iranian Foreign Minister Abbas Araghchi recently stated that “negotiations with the IAEA on resumption of inspections are ongoing.” Parsi says that Tehran, by signaling that the E3 stands to lose whatever influence and leverage it has by taking this route, likely aims to contain the political fallout primarily to its relationship with the three European nations.
This position was made clear in the official response. Araghchi characterized the E3’s move as “unjustified, illegal, and lacking any legal basis.” While firmly stating that Iran would respond “to protect and secure its national rights and interests,” he notably left the door to diplomacy open, expressing hope that the three European countries would “correct this wrong move appropriately in the coming days by adopting a responsible approach and understanding the existing realities.”
However, this calibrated response comes at a steep domestic political cost, empowering Iranian hardliners who argue diplomacy with the West is futile—a case for which the E3’s action provides powerful corroboration.
In addition to reasonable demands—such as full IAEA access to Iranian nuclear sites and disclosure of stockpiles of highly-enriched uranium—one of the E3’s central conditions is the resumption of Iran’s negotiations with the U.S. Yet the E3 is itself a party to the JCPOA and, presumably, capable of diplomatic autonomy. There is no reason it should condition its own stance on bilateral talks between Washington and Tehran, other than a deliberate outsourcing of its own agency.
And while Rubio urges Iran to engage in “serious diplomacy,” there are no signs that Washington itself is pursuing it. In fact, the U.S. and Iran were already engaged in talks when Israel struck Tehran in June, seemingly with a greenlight from President Donald Trump. Those talks had faltered over the Trump administration’s insistence on the Israeli red line of no uranium enrichment for Iran, as opposed to no weaponization. Tehran never accepted and shows no signs of accepting that demand now, even as one of the UN resolutions the E3 has snapped back imposes a ban on Iran’s enrichment.
Ultimately, as Nasri concludes, “The crux of the matter is that the U.S. has outsourced its Iran policy to Netanyahu, and the E3—deprived of strategic autonomy—are reduced to executing Israel’s wanton agenda at the expense of truth, fairness, integrity, diplomacy, and international law.”
But there is more to it: Europe itself may actually prefer the hawkish route as a means of punishing Iran for its support of Russia’s war in Ukraine. While the E3/EU has legitimate reasons to condemn Iran’s role in Ukraine, invoking snapback will do nothing to address that specific grievance. On the contrary, it likely will only push Tehran further into Moscow’s embrace.
There is an alternative. Instead of executing a failed U.S.–Israeli agenda, Europe should champion an extension of UN Security Council Resolution 2231—which suspended sanctions and is due to expire in October—to create space for a reciprocal easing of tensions and an interim deal. Russia and China have, in fact, tabled a relevant resolution to that effect. In essence, it seeks the same goal the E3 claims to pursue—buying more time for diplomacy—but without setting unrealistic conditions virtually guaranteed to result in a diplomatic impasse. According to the Russian diplomat, privately the E3 diplomats have already indicated that they intend to block the Russian–Chinese effort.
If the E3’s goal is to rein in Iran’s nuclear program, avoid war, and peel Tehran away from Moscow, then its gamble is a profound miscalculation. It sacrifices long-term leverage for a short-term show of force, threatens to inflame Tehran’s domestic political tensions, and risks a future where Europe has no seat at the table whatsoever. By triggering snapback, the E3 isn’t preventing a nuclear Iran or a war; it is making both outcomes far more likely, all while surrendering its own strategic autonomy on the world stage.
