Europe Pulls the Snapback Trigger — But on Washington’s Command

On August 28, 2025, the three European members of the JCPOA — Britain, France, and Germany — officially activated the snapback mechanism against Iran. Within the JCPOA, the snapback was designed as a pressure tool: if even one party to the agreement claims that Iran has violated its commitments, the UN Security Council sanctions against Iran can automatically be reinstated. This mechanism, outlined in the JCPOA and UN Security Council Resolution 2231, allows pre-2015 comprehensive sanctions to be restored without any veto power blocking the move. With Europe now having activated the mechanism, several points about this decision must be noted.


1. Europe’s Dependence on the U.S.

Europe’s decision was heavily influenced by American pressure. Since the signing of the JCPOA, Europe has repeatedly shown that despite its political will to preserve the agreement, it lacked the capacity to deliver economically due to its dependence on the U.S. economy. Fear of secondary U.S. sanctions drove European companies out of Iran. Ultimately, Britain, France, and Germany (the E3), in coordination with Washington, agreed on July 14, 2025, that if Iran did not accept the Western-proposed deal by the end of August, they would trigger the snapback mechanism. This coordination is the clearest sign of Europe’s reliance on the United States.


2. Europe’s Inability to Implement the JCPOA

Following Washington’s unilateral withdrawal from the JCPOA, Europe promised to establish mechanisms such as INSTEX. However, this initiative remained symbolic and ineffective. INSTEX, a financial channel between Iran and the European parties, was created after the U.S. exit to prevent Iran from abandoning the deal. Yet in 50 months of operation, INSTEX registered only one transaction among Germany, France, Britain, and Iran. By March 2023, it was formally shut down. Analysis of Iran’s oil exports shows that relying on European promises after the U.S. withdrawal — instead of pursuing strategies to neutralize sanctions — resulted in over $200 billion in lost oil revenue during those 50 months.


3. U.S. Pressure as the Driving Force

The snapback is ultimately a U.S. political tool, not proof of European strength. The decision does not reflect Europe’s independent will but rather its effort to preserve the Western-dominated order, even at the expense of its own economic and security interests. The urgency stems from the fact that both the JCPOA framework and the snapback clause under Resolution 2231 will expire on October 18, 2025. If not invoked before then, the mechanism can no longer be used. For both Washington and Europe, maintaining sanctions is vital to prevent Iran from freely acquiring sensitive nuclear equipment and technology, which they view as directly threatening Western interests.


4. Europe as a Secondary Player in International Politics

In 2020, the Trump administration announced it would activate the snapback. At the time, the E3 explicitly declared that since the U.S. had withdrawn from the JCPOA, it had no legal right to do so. Europe then sought to project an image of independence. Yet in 2025, the same E3 aligned themselves with Washington in reinstating UN sanctions. This reversal demonstrates that Europe’s foreign policy remains subordinate to U.S. political and diplomatic pressure.

In conclusion, Europe’s fear of international isolation and its deep economic interdependence with the United States keep it tethered to Washington in global affairs. The Islamic Republic of Iran is fully aware of this dynamic. Since around 2021, Iran has pursued a sanctions-neutralization strategy — diversifying its foreign policy between East and West and building economic, political, and security partnerships globally. Over the past three years, this approach has helped Iran achieve record oil exports. According to ELine Institute calculations, up to 70% of sanctions pressure has been offset.

Therefore, the activation of the snapback mechanism will not alter Iran’s strategic trajectory.


*Translated by Ashraf Hemmati from the original Persian article written by Hakimeh Zaeem Bashi