Britain, France, and Germany (the E3) have notified the UN Security Council (SC) that they intend to trigger a snapback mechanism under Resolution 2231, which would re-impose UNSC sanctions against Iran. However, the move is being countered by China and Russia.
The sanctions had been lifted in 2015 when Iran signed the Joint Comprehensive Plan of Action (JCPOA), endorsed by Resolution 2231, with the P5+1 group of countries (the USA, UK, France, Russia, and China plus Germany) after years of contentious negotiations moderated by the IAEA. Under the JCPOA, Iran had agreed to limit its nuclear development programme in return for the lifting of sanctions. However, while UN sanctions were duly lifted, those imposed separately by the US and European countries remained in place. Iran, nevertheless, began curtailing its nuclear programme in accordance with the agreement. Then, in 2018 the US unilaterally withdrew from the JCPOA and imposed additional sanctions. In response, after a year of fruitless talks with the E3, Iran, in turn, began rolling back its commitments in line with JCPOA provisions.
The JCPOA is due to expire in October, which would have ended both its commitments outlined in the agreement and any provision for UN sanctions. The E3 move is widely seen as a pre-emptive measure. Once triggered, the snapback mechanism sets a 30-day clock for UN sanctions to be reimposed unless the UNSC votes otherwise. At a closed-door UNSC session, the E3 outlined three conditions they say Iran must meet to delay snapback sanctions for up to six months:
- Restore full access for IAEA inspectors;
- Provide full details of its uranium stockpile; and
- Resume direct negotiations with the US.
The US and E3 had previously set the end of August as the deadline for concluding a nuclear deal with Iran to avoid the snapback mechanism. However, five rounds of nuclear talks between Iran and the US earlier in 2025 yielded no results and were ended in June by Israel’s military operation against Iran and US airstrikes on Iranian nuclear sites. This prompted Iran to ban the IAEA from future access to its nuclear sites, alleging complicity with the US and Israel, and to refuse any further contacts with the US. The E3 subsequently engaged in several rounds of talks with Tehran but failed to broker a new nuclear deal.
The Iranian Foreign Ministry strongly condemned the notification submitted by the E3 to the UNSC seeking to trigger the snapback mechanism. Tehran described the move as “illegal, baseless, and politically motivated”. Iran said the E3 has no authority to resort to the snapback process, noting that the Dispute Resolution Mechanism (DRM) outlined in the JCPOA is a binding, multi-stage consultation framework meant to prevent unilateral abuse and, as the E3 had bypassed this process, it rendered their notification “null and void”.
Iran further accused the three states of serious non-compliance with their own JCPOA obligations following the US withdrawal in 2018, by imposing their own sanctions and failing to deliver economic relief promised under the accord. The ministry warned that the E3’s action undermined Iran’s cooperation with the IAEA and risked “damaging the credibility of the Security Council” while endangering international peace and security. Tehran vowed to respond with “appropriate measures”.
Subsequently, during the Shanghai Co-operation Organisation meeting in Tianjin, China, Iranian Foreign Minister Abbas Araqchi, together with the Chinese Foreign Minister Wangi Yi and Russian Foreign Minister Sergei Lavrov addressed a joint letter to UN Secretary General Antonio Gutteres opposing the E3’s attempt to trigger the JCPOA snapback, calling it “irrational and preposterous”.
The three-page letter stressed that the JCPOA, endorsed by UN Security Council Resolution 2231 “is the unique achievement of multilateral diplomacy and a role model to resolve disputes through dialogue and engagement”. It said the E3’s action “clearly contravenes the resolution, and therefore, it is by default legally and procedurally flawed”. It “abuses the authority and functions of the UN Security Council while misleading its members as well as the international community concerning the root causes of breakdown in the implementation of the JCPOA and the UNSCR 2231”.
The letter continued: “At the inception of the JCPOA, when the “snapback” mechanism was established, it could hardly be foreseen that the US would be the first to break its obligations. The US decision in May 2018 to unilaterally withdraw from the JCPOA and undermine the resolution fundamentally affected the modalities of triggering the “snapback” mechanism that can no longer he used in relation to Iran without properly addressing and resolving in advance the US significant non-performance.”
It noted that the E3 and the EU “not only agreed to comply with the illegal discriminatory US sanctions against Iran but also imposed their own restrictive measures in breach of the UNSCR 2231 and the JCPOA despite their obligations therein”. The letter referred to “a key principle of international law endorsed by the International Court of Justice that ‘a party which disowns or does not fulfil its own obligations cannot be recognised as retaining the rights which it claims to derive from the relationship’.”
By contrast, Iran’s response, including its suspension of implementation of some JCPOA commitments “were taken strictly in response to the US withdrawal and violation of all its commitments and after an extended period of Iran’s continued compliance and the E3/EU inaction in redressing the situation”. The reciprocal steps taken by Iran “cannot serve as a basis for triggering the ‘snapback’ mechanism”. It is “unacceptable that this mechanism is misused to reward the US withdrawal and the subsequent E3/EU failure to uphold their obligations”.
Claims by the E3 that it has exhausted the procedure set out in the JCPOA are false. “The dispute resolution mechanism was not activated due to some procedural gaps that in turn, made it impossible to review the issue”. Bearing this in mind, the re-imposition of terminated UN sanctions on Iran “would only lead to rewarding the E3 for its significant non-performance, undoing years of diplomatic efforts, undermining the credibility of multilateral agreements, and setting a precedent tor selective enforcement of international obligations”.
The letter strongly urged members of the UN Security Council to reject the claims of the E3 “on allegedly invoking the ‘snapback’ mechanism and reaffirm their commitment to the principles of international law and multilateral diplomacy”. It called on the E3 “to change their destructive course, to step back and…to refrain from any action that would only deepen divisions in the UN Security Council or that would have serious adverse consequences on its work”.
The letter concluded: “It is essential that the relevant parties stay committed to finding a political settlement that accommodates the concerns of all parties through diplomatic engagement and dialogue based on the principle of mutual respect, and refrain from unilateral sanctions, threat of force, or any other action that may escalate the situation. We also call on all countries to contribute to creating a favourable atmosphere and conditions for diplomatic efforts.” Iran, Russia and China asked that the letter be circulated as a document of the General Assembly and of the Security Council.
Iranian Foreign Minister Araqchi said Iran is prepared to resume “fair and balanced” negotiations over its nuclear programme, following the E3’s action. In a letter to Kaja Kallas, the EU High Representative for Foreign Affairs, he emphasised that Iran remains open to diplomatic talks – provided the other parties demonstrate genuine commitment, act in good faith, and refrain from measures that could sabotage the negotiations. Otherwise, he said, Iran will take “appropriate” countermeasures.
While Araqchi did not specify what those countermeasures might be, Iranian lawmakers revealed that they are drafting legislation that would see Iran withdraw from the NPT, ban all negotiations with Western countries, and suspend cooperation with the IAEA. However, before the bill can take effect, it must pass Parliament, be approved by the Guardian Council and gain the backing of the Supreme National Security Council.
Meanwhile, the head of Iran’s Atomic Energy Organisation (AEOI), Mohammad Eslami, confirmed that two IAEA inspectors had visited Iran with authorisation from the Secretariat of the Supreme National Security Council. He said the inspectors monitored refuelling at the Bushehr NPP. “This inspection was part of ongoing cooperation with the IAEA, carried out within the framework of parliamentary law and with the council’s approval,” Eslami said, adding that the inspectors “came, supervised the process, and left”.
Eslami noted that negotiations with the IAEA were ongoing, with two meetings held so far and a third planned. However, he criticised the agency’s leadership, saying its governance is “influenced by global powers” and applies “double standards” in monitoring member states. “The important point is that what should be realised according to the parliament’s law is being negotiated at present,” he said.
In a recent podcast, Professor Mohammed Mirandi of Tehran University noted that, even if UN sanctions were reimposed, they would have little effect on Iran because the US and EU sanctions already in effect were much stricter. Moreover, they would be further muted by the fact that neither China nor Russia would comply with them. In any event, he said, the Europeans “have burned their last bridge with Iran”.
