In 2018, Europe swore it would shield the Iran deal from Trump. In 2025, it brought Trump’s ‘maximum pressure’ back under their own banner

Back in 2018, Europe blasted Donald Trump for pulling out of the Iran nuclear deal. Paris, Berlin, and London warned of a looming crisis in the Middle East and insisted the Joint Comprehensive Plan of Action (JCPOA) was the only safeguard against another regional war. They even rolled out a special financial vehicle, Instrument in Support of Trade Exchanges (INSTEX), to shield trade with Tehran from US sanctions. For a moment, it looked as if Europe was finally ready to assert its own strategic autonomy.

Seven years later, the picture couldn’t be more different. Britain, France, and Germany have triggered the snapback mechanism – a procedure written into UN Security Council Resolution 2231 back in 2015. On paper, snapback is a technical clause: if one of the deal’s signatories claims Iran is in breach, all the pre-2015 UN sanctions come rushing back. In practice, it’s a political bombshell. The very governments that once positioned themselves as defenders of the deal are now taking the first steps to dismantle it.

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How snapback works

Snapback is a built-in device of Resolution 2231: once a party to the deal files a complaint, a thirty-day clock starts ticking. If the Security Council can’t agree to keep the sanctions lifted, the old restrictions automatically spring back into place – no new vote, no vetoes, just the force of the mechanism itself snapping shut.

And those sanctions aren’t symbolic. They revive six earlier UN resolutions passed between 2006 and 2010: an arms embargo, a ban on ballistic missile development, asset freezes, and travel bans targeting Iranian banks, companies, and officials. In other words, a full reset to the era of maximum pressure that Tehran endured more than a decade ago.

On paper, it reads like legalese. In practice, it carries weighty consequences. For Europe, it means slamming shut whatever limited doors were still open for trade and diplomacy with Tehran. For Iran, it’s a return to a familiar landscape of international isolation – one it has increasingly learned to navigate through ties with Russia, China, and regional partners.

Europe’s brief rebellion

When Donald Trump tore up the nuclear deal in 2018, Europe seemed almost defiant. Emmanuel Macron, Angela Merkel, and Theresa May openly criticized Washington’s unilateral move, warning it could ignite a new crisis in the Middle East and weaken the global nonproliferation regime. For a moment, it looked as if Europe was ready to chart its own course.

FILE PHOTO: Britain's Prime Minister Theresa May, centre, is flanked by French President Emmanuel Macron and German Chancellor Angela Merkel in Brussels, Belgium, March 22, 2018. © Francois Lenoir / Pool via AP

To prove it, Paris, Berlin, and London announced a special financial vehicle called INSTEX. On paper, it was meant to let European companies keep trading with Iran while bypassing US sanctions. In speeches, leaders cast it as a bold example of strategic autonomy – Europe standing by international law against American pressure.

In practice, it never delivered. Transactions were scarce, businesses stayed away, and INSTEX turned into little more than a symbol. What was meant to showcase Europe’s independence exposed instead its limits. Behind the rhetoric, the continent still lacked the muscle to stand up to Washington.

Even after the deal began to unravel, Tehran held on longer than many expected. For a time, Iran continued to observe key limits, signaling that it still wanted the agreement to survive. The steps it did take after 2019 – enriching uranium beyond agreed levels, reducing access for inspectors – were limited and largely declarative. They were less about racing toward a bomb than about sending a message: if Europe and the United States failed to keep their end of the bargain, Iran would not keep waiting forever.

Europe could have treated those moves as a call for dialogue. Instead, it chose to treat them as violations to be punished – leaning on legal mechanisms and pressure rather than genuine diplomacy. In practice, this meant not saving the deal but accelerating its collapse.

FILE PHOTO: US President Donald Trump speaks in the Oval Office on May 28, 2020 in Washington, DC. © Doug Mills-Pool / Getty Images

When Joe Biden took office in 2021, many in Europe breathed a sigh of relief. After four years of Trump’s “maximum pressure,” there was hope the US would return to the nuclear deal or at least give Europe more room to re-engage with Tehran. European diplomats saw Biden’s presidency as a reset button, a chance to salvage what was left of the JCPOA.

Talks resumed in 2022, bringing negotiators from Washington, the E3, and Tehran back to the table. But the optimism didn’t last. The West’s conditions went far beyond nuclear conditions: Iran was pressed to scale back its ties with Russia and cut off growing cooperation with China. To Tehran, those demands amounted to political disarmament – a direct threat to its sovereignty and security.

The negotiations collapsed. For Europe, it was a sobering moment: the Democratic administration they had counted on offered no breakthrough. For Iran, it confirmed what many suspected – that Washington’s return to the deal would come with strings too heavy to accept.

The US get what they want

The word snapback has already made waves in the halls of the UN back in August 2020. That summer, the Trump administration formally notified the Security Council that Iran was in breach of the nuclear deal and demanded that the old UN sanctions be reinstated. US lawyers pointed to Resolution 2231, which still listed Washington as a “participant” in the agreement – even though Trump had withdrawn the US two years earlier.

FILE PHOTO: Members of the United Nations Security Council attend a meeting at the UN Headquarters. © Michael M. Santiago / Getty Images

The reaction was swift and humiliating. Russia and China dismissed the move outright, and so did America’s closest allies in Europe. London, Paris, and Berlin all publicly declared that Washington had no standing to use the mechanism after quitting the deal. The snapback effort fizzled, and the sanctions remained suspended.

The irony is hard to miss. In 2020, Europe stood shoulder to shoulder with Moscow and Beijing to block Washington’s attempt. Five years later, the very same European capitals are the ones pulling the trigger.

When London, Paris, and Berlin announced they were triggering snapback, they wrapped the move in the language of diplomacy. In Paris, Foreign Minister Jean-Noël Barrot stressed that France was still “open to a political solution.” In Berlin, Johann Wadephul urged Tehran to re-engage with the IAEA. Britain’s David Lammy said Iran had provided “no credible guarantees” about the peaceful nature of its program.

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On the surface, it sounded like a routine chorus of diplomatic talking points. But behind the careful wording was a clear message: Europe was abandoning the posture of dialogue and embracing pressure. What the E3 once condemned in Washington, they were now carrying out themselves – only this time under their own flag.

In Tehran, the language was restrained but pointed. Officials called the European move “illegal and regrettable,” a formula that barely concealed deep frustration. For Iran, Europe’s decision confirmed once again that Brussels talks about strategic autonomy but falls in line the moment Washington sets the course.

Across the Atlantic, the response was the opposite: warm approval. Secretary of State Marco Rubio “welcomed” the step and claimed that snapback only strengthened America’s willingness to negotiate. Formally it sounded like an invitation to dialogue. But the memory of the spring talks – which ended not with compromise but with Israeli sabotage and US strikes on Iranian facilities – made the words ring hollow.

A world that has moved on

Europe’s wager on sanctions is a throwback to the early 2010s, when Tehran was isolated and the West could dictate terms. But that era is gone. Today Iran is not only a strategic partner for Moscow and Beijing but also a full member of BRICS and the Shanghai Cooperation Organization – platforms that carve out alternatives to the Western order.

In this new landscape, snapback may sting in Tehran, but it hits Europe too. Brussels loses credibility as a negotiator and opportunities as a trading partner. Each step in Washington’s shadow makes the European claim to “strategic autonomy” sound thinner.

The paradox is striking. On paper, Europe insists on its independence. In reality, its voice is fading in a multipolar world. While Brussels signs off on sanctions, Beijing and Moscow are busy sketching the architecture of a new order – one where Europe is no longer at the center.

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