Possible options to prevent snapback of sanctions:
New deal or extension of Resolution 2231
October 2025 marks the expiration of Resolution 2231 and the complete lifting of United Nations Security Council resolutions against Iran. Meanwhile, the three European countries that are parties to the 2015 Joint Comprehensive Plan of Action (JCPOA) recently warned Tehran about the potential activation of the snapback mechanism during a INSC meeting in December.
Germany, France, and the UK issued a caution to Iran regarding the so-called “snapback” mechanism being triggered during the periodic six-month session of the Security Council on Resolution 2231.
In a statement, the European members of the JCPOA declared, “We are prepared to use all diplomatic tools, including snapback, if necessary, to prevent Iran from acquiring nuclear weapons.”
This comes as the US itself unilaterally withdrew from the JCPOA in 2018, which disrupted the full implementation of the agreement. As a result, starting from that point—especially after Iran began scaling back its commitments under the JCPOA in 2019—ambiguities surrounding this ten-year timeline emerged.
The Geneva talks involving Iranian Deputy Foreign Minister Majid Takht-Ravanchi and representatives from the UK, France, and Germany took place in December, following a contentious resolution passed by the International Atomic Energy Agency’s Board of Governors. This resolution demands a report on Iran’s nuclear program and its lack of full cooperation with the IAEA by spring 2024. This resolution, marking the second such action against Iran in two years, has prompted Iran to announce it will activate new and advanced centrifuges as a retaliatory measure.
Iran’s Foreign Ministry spokesperson, Esmaeil Baghaei, issued a warning regarding the potential misuse of the snapback mechanism relating to the JCPOA, which could reinstate suspended sanctions.
“Any attempt to exploit the snapback mechanism will be met with a reciprocal response from Iran.”
Also, Takht-Ravanchi warned Tehran would withdraw from the Nuclear Non-Proliferation Treaty if a so-called snapback mechanism renews the UN sanctions lifted by the 2015 nuclear deal.
Regarding the potential use of the snapback mechanism by the European countries, the spokesperson for the National Security and Foreign Policy Commission of Parliament Ebrahim Rezaei, has recently said “According to our diplomats [Takht-Ravanchi and Kazem Gharib Abadi], the day this issue is activated, the Islamic Republic will invoke Article 10 of the NPT, and we will not accept any preconditions in negotiations.”
According to Article 10 of the NPT, “If any member of the treaty determines that extraordinary events related to the subject of this treaty have jeopardized its national interests, it shall have the right to withdraw from the treaty in exercising its national sovereignty.”
To examine the trajectory of negotiations between Iran and the three European countries, as well as the possibility of Iran withdrawing from the “Treaty on the Non-Proliferation of Nuclear Weapons,” an interview was conducted by IRNA with Kourosh Ahmadi, an international relations analyst and former diplomat at the UN, which is presented as follows:
Only a new deal
can prevent snapback
The significance of the snapback mechanism in the West’s calculations during the quest for a new agreement with Iran before the October 2025 deadline is paramount. For Western countries, including the US and Europe, the snapback mechanism is a crucial issue; it seems that the only way to potentially avert it is if Iran and the West reach an agreement, with its terms finalized by late summer. Otherwise, it is highly unlikely that any measures to stop this mechanism will be successful.
The Western assumption is that Iran’s nuclear program has advanced significantly. They believe that Iran’s stockpile of 60% enriched uranium has reached a level sufficient to allegedly produce four or five bombs. Given that Tehran possesses such an advanced nuclear program, it is very unlikely that the West will allow the issue of Iran to be taken off the Security Council’s agenda without an agreement.
The snapback mechanism is of great importance to the West, including the US and Europe; it may only be possible to avoid the return of sanctions if Iran and the West come to an agreement with the terms finalized by late summer. The West wants to keep the issue of Iran on the Security Council’s agenda.
The matter of snapback and the return of seven Security Council resolutions against Iran is just one aspect of the situation. The crux of the issue is that, according to paragraph 8 of Resolution 2231, the validity of this resolution will expire on October 18, 2025. If this occurs, the issue of Iran will be removed from the Security Council’s agenda, and Iran’s nuclear program will return to a normal status.
Should this happen, given the global dynamics and the new wave of competition among major powers at that time, it is possible that the West will not be able to bring Iran back to the Security Council due to vetoes from Russia and China. Therefore, the non-utilization of the snapback mechanism by the West would mean that the issue of Iran is effectively off the Security Council’s agenda. For this reason, the West, citing the problems it claims to have with Iran, is striving to keep the issue of Iran on the Security Council’s agenda.
Extension of expiration date
In this context, the only way [for the Europeans] to prevent Iran’s nuclear program from being taken off the Security Council’s agenda and to avoid the permanent expiration of Security Council resolutions against Tehran is through the implementation of the snapback mechanism. Thus, the key issue is that the only way [for Iran] to sidestep the snapback is to reach an agreement between Iran and the West. This means that Iran and the West should find a way, whether through the same 1+5 format or, following the US withdrawal from the JCPOA, through the 1+4 framework, to revitalize the JCPOA or reach a new agreement that eliminates the necessity for Iran to remain on the Security Council’s agenda. In such a case, the snapback will naturally be off the table. However, if both parties do not come to an agreement about two months prior to October 18, 2025, another possibility could arise: the West may agree to delay the expiration date of Resolution 2231. This would entail the three European countries presenting a formal resolution to the Security Council to extend the October 18 deadline by six months to a year, allowing more time for negotiation.
Threatening withdrawal from NPT
Given the explanations provided, it seems unlikely that simply threatening to withdraw from the NPT would suffice to prevent the snapback mechanism. This means that Iran’s exit from the Treaty on the Non-Proliferation of Nuclear Weapons would be a legal action, and it is unclear whether such a withdrawal would indicate an intention to pursue nuclear weapons. This scenario echoes North Korea’s actions in April 2003 when it expelled inspectors from the IAEA and conducted its first nuclear test about three years later. The situation in our region is different from that of North Korea. The geopolitical landscape in Northeast Asia has led the West and the US to ultimately back down, even though they imposed conditions on North Korea that we are all aware of. However, regarding Iran, the dynamics are complicated by the regional context, including the positions of Arab countries, Turkey, and the issue of Israel, making it uncertain whether events would unfold in the same manner. Nonetheless, the involved parties have threatened that, in such a case, they would resort to military action, and one could speculate about the positions China and Russia would take in that scenario.
West’s assumption of complete insight into Iran’s nuclear program
Another consideration for the West, as implied in their rhetoric, is that they claim to have complete intelligence on the situation within Iran and can guess whether Iran intends to move toward nuclear weapons. They believe that if a decision is made in this regard, it will not remain hidden from them. Their assumption is that in such a case, they would face the issue more comfortably and would not necessarily have a problem with Iran’s withdrawal from the NPT, as the act itself, in legal terms, would be significant and might not indicate a move toward bomb-making.
In terms of Europe’s role, Trump’s position is crucial, and it remains to be seen how he will collaborate with Europe in this area and whether the Iran issue will become one of the few points of convergence between Europe and the Trump administration. The Europeans may also wish to leverage this card in negotiations with the US.
Only two options ahead for Iran
The challenge is that we are currently facing the October 18, 2025 deadline, which means both parties must either reach an agreement before that date or, if possible, extend the deadline. While this extension is a feasible option, it carries its own legal risks—altering Security Council texts, which are intricately drafted, could pose significant issues. Ultimately, these are the only two solutions available to prevent the snapback mechanism.
Possible influence of Russia-Europe row
One of the key issues is how the format of the upcoming negotiations will take shape. Previously, the negotiating parties included the Security Council countries plus Germany. After the US unilaterally withdrew from the JCPOA, the format shifted to 1+4. The question now is whether this format can continue in the future and whether its continuation would even serve our interests. The Europeans will likely express their unwillingness to sit at the table with Russia, as they believe that Russia has jeopardized European security, with its invasion of Ukraine being an attack on Europe as a whole. As far as I know, this matter has not yet been thoroughly examined.
China, Russia lack leverage in negotiations
In reality, the core issue lies between Iran and the United States, with the main sanctions against Iran imposed by the US. The question arises: given this situation, is it even necessary for other parties to be involved in the negotiations? Of course, the snapback mechanism is in the hands of the Europeans, and from this perspective, an agreement with them is essential. However, China and Russia bring nothing to the table, whether positively or negatively, regarding the negotiations, and at one point, the Russians even hampered the 2015 JCPOA talks, as Mr. Zarif has pointed out. During the discussions to revive the JCPOA, the former foreign minister, Hossein Amir-Abdollahian, explicitly stated in an interview with Al-Mayadeen in March 2023 that “We were on the verge of reaching an agreement when the Ukraine war broke out and everything changed”. Countries like China and Russia may exert influence on Iran through pressure, but they hold no significant leverage in the 1+4 and 1+5 negotiation formats. They have neither sanctioned us nor are they likely to oppose the lifting of sanctions against Iran as permanent members of the Security Council. From the outset, we sought their presence, perhaps with the consideration that we wouldn’t negotiate solely with the US, thus giving rise to such a format. While European sanctions were also in place at that time, the involvement of Russia and China was not particularly relevant. It’s possible that we may reach a format in which Russia and China are not present at all.
US-European cooperation in JCPOA revival
Regarding Europe’s role, US President Donald Trump’s stance is significant; we need to see how he collaborates with Europe on this front and whether the Iran issue will become one of the few points of common ground between Europe and the Trump administration. The Europeans may also want to leverage this card in their dealings with the US.