TEHRAN – The 2015 Iran nuclear deal (officially the Joint Comprehensive Plan of Action, or JCPOA) contains a "snapback" mechanism, which allows any signatory to reinstate pre-existing UN sanctions against Iran if they determine that the country is not staying true to the agreement. 

Following its withdrawal from the JCPOA in 2018 and subsequent reimposition of sanctions against Iran, Washington forfeited its legal right to invoke the JCPOA's snapback mechanism. Under the agreement, Iran had committed to limiting its nuclear activities in exchange for the termination of sanctions, making the U.S. withdrawal a significant setback to the deal's success.

The remaining non-Iranian signatories – Germany, Britain, France, China, and Russia – arguably have a strong incentive to avoid triggering the snapback. Tehran has threatened to consider withdrawing from the NPT if the snapback is invoked, arguing that it only began to scale back on some of its JCPOA commitments after the U.S. withdrawal and the subsequent failure of the remaining signatories to adequately mitigate the impact of Western sanctions. Furthermore, Iran maintains that it continues to fully cooperate with the IAEA and has not initiated efforts to develop nuclear weapons.

Given these circumstances, if Iran upholds its remaining JCPOA commitments and refrains from further escalating its nuclear activities, why would other parties risk provoking a drastic response by triggering the snapback mechanism? Iran already faces heavy sanctions, and the pre-existing UN sanctions would likely have minimal additional impact. Thus, why force a potential withdrawal from the NPT? While many struggle to understand why the European trio might still be willing to escalate tensions, the latest U.S. actions, widely perceived as a humiliation for Europe regarding Ukraine, offer a clue.

When the war in Ukraine began in early 2022, European powers were forced to wean their economies off Russia and pour billions of dollars into Ukraine to help Kyiv fight Washington’s proxy war. Subsequently, Europeans experienced unprecedented inflation and saw their economies enter recession, with the long-term outlook for the continent suggesting more trouble ahead. 

Today, however, it appears that U.S. President Donald Trump is cutting a deal with Russia on the war with Ukraine, and he does not care if Europeans are willing to be a part of it. When Americans and Russians convened in Riyadh this month to discuss an end to the war, neither Europe nor Ukraine were allowed to sit at the negotiating table. Recently, Trump also killed a UN resolution proposed by the European trio that condemned the Russian invasion.  

There is not much Europe can do about its current lame-duck state – if we were to put aside the tears the chairman of the Munich Security Conference shed as he gave a speech at the end of the summit earlier this month. This reality may help us understand why Europe continues to escalate tensions with Iran, despite knowing that the outcome will not benefit it.

“The reality is that the European Union and Britain cannot act independently from the United States on the international stage,” said Mehdi Khanalizadeh, West Asia analyst and scholar. “Christoph Heusgen’s crying at Munich demonstrated this fact. Europe does not want to let Russia win in Ukraine. But it has no option but to proceed with the plans Washington has rolled out for it.” 

Iran and political representatives from Germany, France, Britain, and the EU have held multiple rounds of talks on various issues, including the fate of the JCPOA, since last year. Kazem Gharibabadi, Iran's deputy foreign minister for legal and international affairs, has told Iranian media that a new round of talks is likely to be held within three weeks. Khanalizadeh, however, believes the potential activation of the snapback depends on Washington, rather than the results of the ongoing negotiations. 

“Europe’s military and security is largely dependent on the United States. If they are told to activate the snapback mechanism, they will do that even if they reckon that the move does not align with their interests,” the expert stated.