As the UK, France and Germany trigger the UN’s “snapback” mechanism on Iran, the stage is set for a decisive test of diplomacy, deterrence and the future of non-proliferation
Azmat Ali
THE United Kingdom, France, and Germany have begun the JCPOA’s “snapback” mechanism, setting a 30-day countdown to decide whether to reimpose the full suite of UN sanctions suspended under the 2015 nuclear deal or allow relief to Iran. They formally notified the UN Security Council on 28 August 2025, accusing Iran of breaching its obligations.
The process is straightforward: the notifying state informs the UN Secretary-General, triggering a 30-day clock. To keep sanctions suspended, the Security Council must adopt a new resolution — but any permanent member can veto it. If no resolution passes, all prior sanctions return automatically. The mechanism was designed to be “veto-proof”: continuation of sanctions relief requires a new Council resolution, which a single permanent member can block.
On 19 September, the Security Council voted on a draft resolution tabled by South Korea to block the automatic reimposition of sanctions. The resolution failed to gain the necessary nine votes, with only four members voting in favour and nine against. As a result, the path is now cleared for the snapback to take effect when the 30-day period ends on 28 September, unless a new resolution intervenes.
E3 Versus Tehran
The E3 argued that Tehran had significantly exceeded allowed stockpiles and was refusing to grant necessary IAEA access. They said Iran had “no civilian justification” for its highly enriched uranium — purified close to military grade — and that its nuclear programme “remains a clear threat to international peace and security.”
These assertions follow IAEA reports confirming uranium enriched up to 60% — far above civilian needs — though the agency has found no evidence of a systematic weapons programme. Western officials warn that Iran’s nuclear advances are already beyond the deal’s framework, making sanctions relief politically untenable.
Tehran swiftly rejected the claims. Foreign Minister Abbas Araghchi called the step “unjustified,” saying it undermined cooperation with the IAEA and lacked any legal basis.
Resolution 2231 reaches its Termination Day on 18 October. After that, the snapback route will no longer be available. This is why the E3 views the current period as the last multilateral legal tool. Moscow and Beijing, however, have circulated draft language to extend the resolution’s implementation for six months, arguing that diplomacy deserves more time.
Diplomats now acknowledge that with the failure of the 19 September resolution, the likelihood of snapback being formally triggered at the end of the month is high. European officials insist that Iran still has a narrow window to de-escalate by taking verifiable steps, but no compromise has yet emerged.
Consequences if Snapback Takes Effect
If implemented, sanctions from six earlier Security Council resolutions (2006–2010) would be revived, covering arms transfers, missile-related activity, asset freezes and travel bans. These measures would carry significant economic and strategic impact, though their effectiveness depends on states’ enforcement.
If not implemented, Iran would retain scope to advance its nuclear and military programmes while benefiting from sanctions relief and expanded trade — shifting regional power balances and reducing Western leverage.
Domestic Defiance in Tehran
Inside Iran, leaders frame snapback as an assault on sovereignty. Nationalist rhetoric portrays enrichment as a right under the Non-Proliferation Treaty, blunting public frustration with sanctions and recasting defiance as patriotic resistance. Officials warn that renewed sanctions could trigger retaliation: raising enrichment above 60%, restricting IAEA access, or even withdrawing from the NPT altogether.
This defiance is not only rhetorical. The June 2025 strikes — repeated Israeli attacks on nuclear facilities, followed by US strikes and Iranian retaliation — hardened hardline narratives that resistance is strength. Snapback, therefore, arrives in a political atmosphere where Iranian leaders feel compelled to project defiance, not accommodation.
Russia, China and the
Geopolitics of Enforcement
Russia and China immediately condemned the E3’s decision. Both framed their opposition as protecting diplomacy, but their deeper motives are strategic: Russia has relied on Iranian drones in Ukraine and deepened energy and arms cooperation, while China has boosted oil imports from Iran and values Tehran as a Belt and Road partner.
In practice, their support ensures snapback will be difficult to enforce. Even if UN sanctions formally return, Moscow and Beijing can continue trading with Iran, undermining the measures and leaving Europe and Washington to shoulder enforcement. For Tehran, this backing reinforces its claim that the E3’s action is illegitimate.
Escalation Risks
If snapback takes effect, sanctions will cover arms imports, banking and enrichment. This could sharpen confrontation. Israel, having already struck Iranian facilities in June, could invoke UN authority to justify renewed attacks. The United States, though cautious, may support “enforcement” actions if Iran defies Council resolutions. Tehran could escalate enrichment or restrict inspectors entirely, raising fears of a nuclear “race against time.”
The risks extend beyond war. Renewed sanctions would deepen Iran’s economic crisis. Historically, such pressure has strengthened hardline factions that thrive on foreign confrontation.
Credibility at Stake
For Europe, triggering snapback is about salvaging credibility after Washington’s 2018 withdrawal. For Tehran, rejecting it is about sovereignty and resilience. For Washington, the dilemma is that unilateral US sanctions already cover much of the same ground, raising doubts about what snapback adds.
For smaller states, the lesson may be that international agreements are fragile and enforcement unreliable, undermining trust in non-proliferation norms. Europe sees snapback as its last tool; Tehran sees it as coercion. The coming weeks will show whether diplomacy survives or confrontation deepens.
As of 21 September 2025, the countdown is entering its final week. With the Security Council failing to block reimposition, sanctions are set to automatically return on 28 September unless unexpected diplomatic breakthroughs occur. President Emmanuel Macron and German Chancellor Olaf Scholz have both publicly stated that “time is almost up” for Iran to show restraint.
At its core, the snapback debate is about credibility: of agreements, institutions and deterrence. If sanctions return and Iran defies them with support from Russia and China, the UN risks looking toothless. If sanctions lapse with Termination Day, the last binding tool for restraining Iran disappears. Either way, the authority of the global non-proliferation system will be weakened.
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Azmat Ali writes in English and Urdu, with a focus on literature, politics, and religion. Views expressed here are author’s personal. He can be contacted at rascov205@gmail.com and @azmata90_lle (Instagram ID)
