Members of Security Council vote during SC meeting on situation in Gaza on resolution put forward by Algeria at UN Headquarters in New York on February 20, 2024

The Shadow of the “Trigger Mechanism” over Iran

Following the 12-day war between Israel and Iran, criticism of the International Atomic Energy Agency (IAEA) and its director general, Rafael Grossi, intensified in Iran. Iranian officials accused the IAEA of failing to protect their nuclear facilities and of being biased in their reporting on Iran’s nuclear programme specially having stockpiled 408.6 kilograms of 60% enriched uranium. From the perspective of Iranian officials, the recent IAEA report and the subsequent resolution against Iran on 12 June, paved the way for potential Israeli attacks on Iranian nuclear facilities. They view the IAEA’s actions as politically motivated, providing a justification for the strikes.[i]

In a direct response to recent attack by Israel and the United States on Iranian nuclear facilities and also the IAEA’s approach and performance, Iran’s parliament passed legislation to oblige the Iranian government to suspend cooperation with the IAEA on 25 June. However, this cooperation has been “suspended”, not altogether banned. Following the implementation of this law, IAEA inspectors left Iran, but Iran’s cooperation with the organization will continue. In fact, Iran’s mission to the IAEA is active in Vienna and acts as a bridge between the Atomic Energy Organization of Iran and the IAEA. In this regard, Massimo Aparo, Deputy Director General of the IAEA and Head of the Department of Safeguards, travelled to Iran to discuss continuing cooperation between Iran and the agency on 11 August.

However, while the ceasefire between Iran and Israel is very fragile, the possibility of a new war between the two sides is very high. Concurrently, there is no clear prospect of nuclear negotiations between Iran and the United States. The threat of using the “Trigger Mechanism” or “Snapback Mechanism” by the JCPOA’s European troika – France, Germany and Britain – has increased, which is also supported by the United States and Israel. This mechanism, which is included in the JCPOA as the “Dispute Resolution Mechanism” and has been given an operational aspect in paragraphs 11 and 12 of UN Resolution 2231, is a tool that allows the member states of the agreement to initiate a formal process to restore international sanctions in the event of Iran’s violation of its obligations.

In this regard, French Foreign Minister Jean-Noel Barrot on 15 July warned that without a “firm, tangible, and verifiable commitment” from Iran, they would reapply embargoes “by the end of August at the latest”.[ii] If the “trigger mechanism” is implemented, all the six sanctions resolutions of the Security Council against Iran before 2015 (resolutions 1696, 1737, 1747, 1803, 1835, and 1929), will return in one place, which will be a great shock to Iran’s economy.

The European troika of the JCPOA and the threat of the trigger mechanism

Following the decision of Donald Trump to unilateral withdrawal from the JCPOA on 8 May 2018 and the imposition of a policy of “maximum pressure” against Iran, the United States attempted to trigger the “snapback mechanism” in UN Security Council Resolution 2231 to restore all UN sanctions on Iran. However, the effort failed in September 2020 as the majority of the Security Council members, including all other parties to the JCPOA, rejected the motion, asserting that the U.S., having withdrawn from the JCPOA, was no longer a participant and therefore lacked the legal grounds for invoking the snapback mechanism.[iii] The U.S. secured support only from the Dominican Republic.

Yet five years later, the landscape has shifted sharply. Relations between Tehran and the European JCPOA signatories – France, Germany, and the UK – have deteriorated to their lowest point since the 1979 Islamic Revolution. One month before the Israeli attack on Iran and in the midst of indirect negotiations between Iran and the United States, the French Foreign Minister laid down the gauntlet in a speech to the Security Council on 29 April: If European security is threatened, Paris “will not hesitate for a single second to reapply all the sanctions that were lifted 10 years ago.”[iv]

Following the 12-day Israel-Iran war, the United States’ bombing of Iran’s nuclear facilities and Iran’s suspension of cooperation with the IAEA, the European troika’s threat to activate the trigger mechanism has intensified, which also enjoys the support of the United States and Israel. In this regard, Foreign Minister Barrot on 15 July again warned that without a “firm, tangible, and verifiable commitment” from Iran, they would reapply embargoes “by the end of August at the latest”.[v] In addition, the UK, France and Germany have agreed to restore tough UN sanctions on Iran by the end of August if there will have been no concrete progress on a nuclear deal, two European diplomats said on 15 July.[vi] The three countries’ ambassadors to the United Nations met on at Germany’s UN Mission to discuss a possible Iranian deal and reimposing the sanctions. The matter also came up in a phone call on 14 July between U.S. Secretary of State Marco Rubio and the foreign ministers of the three countries, according to two U.S. officials.[vii]

In addition, Michael Waltz, Donald Trump’s nominee for U.S. ambassador to the United Nations, told a Senate Foreign Relations Committee hearing on 15 July that “activating the trigger mechanism is one of his priorities at the United Nations. We have spoken to Germany, Britain and France and I am absolutely confident that they will cooperate with us”.[viii] The Israeli government has also called on the European E3 powers to impose their “snapback” sanctions on Iran.[ix]

A crucial point is that the “trigger mechanism” or “snapback” does not require a new vote in the UN Security Council and the consensus of its five permanent members, because it has already been foreseen and approved as part of the JCPOA. Therefore, Iran cannot count on the veto of its eastern allies, Russia and China on this instance.

The snapback mechanism, along with all other provisions of Resolution 2231, is scheduled to expire on 18 October 2025. After this date, if Iran violates the JCPOA, the UN will no longer have the ability to automatically reimpose sanctions. Any reimposition of sanctions would require a new Security Council resolution, which could be subject to a veto by any of the permanent members.[x] Therefore, since the process of approving the trigger mechanism takes 30 days, the European troika of the JCPOA plan to raise this mechanism in late August if Iran and the United States fail to reopen negotiations. As a result, in late September, the trigger mechanism will be implemented and all six resolutions against Iran from before 2015 will be returned to power.

After the trigger mechanism: Iran's withdrawal from the NPT and the escalation of tensions

The trigger mechanism is a pressure tool from the European troika to return Iran to the negotiating table. Important factors have prevented renewed talks between Iran and the United States, including Tehran’s emphasis on continuing enrichment inside Iran, the U.S. and Israel’s insistence on zero uranium enrichment and the transfer of 408.6 kilograms of 60% enriched uranium outside Iran, as well as Iran’s opposition to the broader agenda of negotiations on missile capabilities and proxy groups in the Middle East. Israel’s 12-day war with Iran, as well as the United States’ attack on Iranian nuclear facilities, have exacerbated the climate of distrust between Tehran and Washington.

The attack on Iran took place in the middle of indirect negotiations between Iran and the United States. In this regard, Iran’s Foreign Minister Abbas Araqchi said that “they should explain why they attacked us in the middle of negotiations. They have to ensure that they are not going to repeat that (during future talks)”.[xi] In these circumstances, the “Trigger Mechanism” serves as a “Sword of Damocles” by the JCPOA’s European troika. In fact, Western parties hope that as economic problems intensify, Iran will be forced to return to the negotiating table and a new agreement will be reached between Iran and the United States.

After Donald Trump unilaterally withdrew from the JCPOA, Iran was subject to unilateral U.S. sanctions. Sanctions on shipping and aviation were also imposed against Iran by the European Union, in the context of Tehran’s support for Moscow in the latter’s war in Ukraine. But reviving the trigger mechanism would put Iran back under Chapter VII of the UN Charter and Security Council sanctions. The return of Security Council sanctions could have a negative impact on Iran’s foreign trade with other non-Western countries, especially in the Middle East and Asia, and could reduce the volume of Iranian oil exports to China too. In such circumstances, a decline in the value of the rial against foreign currencies, especially the U.S. dollar, could lead to increased inflation, reduced purchasing power, and an increase in the budget deficit.

According to aforementioned threats and challenges, Iran has voiced strong opposition to the trigger mechanism, viewing it as “illegal” and “illegitimate”. In this regard, Iranian Foreign Minister Abbas Araqchi, in response to the French Foreign Minister’s threat to activate the trigger mechanism, said: “From our perspective, this action would be equivalent to a military attack”.[xii] However, Iran continues to try to convince the European troika not to activate the trigger mechanism. In this regard, Iran and the European countries resumed negotiations on 25 July in Istanbul. The meeting was held at the level of deputy foreign ministers.[xiii]

It seems that these negotiations failed to bring about adequate results as the European troika told the United Nations on 13 August that they are prepared to reinstate sanctions on Iran, according to a joint letter.[xiv] Undoubtedly, Iran has a very difficult path ahead. On the one hand, relations between Tehran and the European JCPOA signatories have considerably deteriorated. Although Massimo Aparo, Deputy Director General of the IAEA and Head of the Department of Safeguards visited Iran on 11 August to discuss continuing cooperation between Iran and the agency,[xv] there is no clear sign of an agreement between Iran and the European troika to prevent the trigger mechanism at the end of August.

It seems that if the trigger mechanism is implemented, one of the most likely reactions from Iran could be to withdraw from the Treaty on the Non-Proliferation of Nuclear Weapons (NPT). Senior Iranian officials have warned against such a decision. For example, Amir Saeed Irvani, the Islamic Republic’s ambassador and permanent representative to the United Nations, threatened the Security Council in a letter on 11 June that Tehran would withdraw from the NPT if the snapback mechanism is activated.[xvi]

The dangerous consequences of withdrawing from the NPT, could be intensifying the policy of “nuclear ambiguity” and even finalizing Iran’s withdrawal from the IAEA. If the fragile ceasefire between Iran and Israel continues, the European troika does not activate the trigger mechanism, and Iran and the United States reach an agreement, Iran could return to the status quo preceding the Israeli attacks.

The experience of the JCPOA indicates that reaching an agreement is possible in an atmosphere free of tension and threats, and based on mutual interests. Therefore, in a situation of uncertainty and extreme vulnerability, the coming months are very sensitive, and any decision to “escalate” or “de-escalate” the situation will depend on the actions and reactions of the parties involved. Mohammad Javad Zarif, Iran’s minister of foreign affairs (2013-2021) who played a key role in negotiating the JCPOA agreement in 2015, in his recent article in Foreign Policy titled “The Time for a Paradigm Shift Is Now”, argued that “The United States and Europe — and not just Iran — have an existential interest to encourage the paradigm shift. By opting for war even as negotiations were underway, they have practically slammed the door on diplomacy. The onus is now on them to change course if they expect Iranian reciprocation. Iran, too, has much to gain — and immense hardship to avert — by engaging in a multidimensional, forward-looking, results-oriented dialogue. The path forward may include the formation of a regional network for nonproliferation and peaceful nuclear cooperation, coupled with a possible U.S.-Iran non-aggression pact”.[xvii]

Conclusion

Therefore, it seems that a minimum of confidence-building is needed for the parties to return to the negotiating table to prevent another devastating war — which could be much more widespread and severe than the 12-day war between Israel and Iran. In this regard, the first step is to assure Iran that it will not face a renewed military attack from Israel and the United States in the midst of the new round of negotiations Iran should not feel that the negotiations are a deception or a cover for war.  The next and complementary step is for the European troika to avoid activating the trigger mechanism to prevent an escalation of tensions and to create space for a new round of negotiations between Iran and the United States. In these circumstances, it can be expected that Iran and the United States will be able to start negotiating a new agreement.

[i] Al Jazeera (2025). “Iran hardens stance against IAEA and its chief in wake of US-Israel attacks”, 30 June 2025, retrieved from: https://www.aljazeera.com/news/2025/6/30/iran-hardens-stance-against-iaea-and-its-chief-in-wake-of-us-israel-attacks.
[ii] Anadolu Agency (2025). “France signals reapplying embargoes on Iran if no tangible nuclear deal achieved”, 15 July 2025, retrieved from: https://www.aa.com.tr/en/europe/france-signals-reapplying-embargoes-on-iran-if-no-tangible-nuclear-deal-achieved-/3631205#.
[iii] Talmon, S. (2021). “Germany opposes U.S. interpretation of UN Security Council resolution 2331”, German Practice in International Law (GPIL), 2 November 2021, retrieved from: https://gpil.jura.uni-bonn.de/2021/11/germany-opposes-u-s-interpretation-of-un-security-council-resolution-2331-2015/.
[iv] Reuters (2025). “France won’t hesitate to restore UN sanctions on Iran if no deal, says foreign minister”, 29 April 2025, retrieved from: https://www.reuters.com/world/france-wont-hesitate-restore-un-sanctions-iran-if-no-deal-says-foreign-minister-2025-04-29/.
[v] Anadolu Agency (2025). “France signals reapplying embargoes on Iran if no tangible nuclear deal achieved”, 15 July 2025, retrieved from: https://www.aa.com.tr/en/europe/france-signals-reapplying-embargoes-on-iran-if-no-tangible-nuclear-deal-achieved-/3631205#.
[vi] The Associated Press (2025). “France, UK and Germany would restore UN sanctions on Iran next month without progress on a deal”, 16 July 2025, retrieved from: https://apnews.com/article/iran-un-sanctions-snapback-uk-france-germany-f9458505b67698935625185532fa5a0f.
[vii] The Associated Press (2025). “France, UK and Germany would restore UN sanctions on Iran next month without progress on a deal”.
[viii] Iran International (2025). “Michael Waltz considers activating the trigger mechanism one of his priorities at the UN”, (in Persian), 15 July 2025, retrieved from: https://www.iranintl.com/202507154809.
[ix] All Israel News (2025). “Israel calls on the UK, Germany and France to impose earlier snapback sanctions on Tehran”, 17 July 2025, retrieved from: https://allisraelnews.com/israel-calls-on-the-uk-germany-and-france-to-impose-earlier-snapback-sanctions-on-tehran.
[x] Arms Control Association (2025). “The Art of a New Iranian Nuclear Deal in 2025”, 17(1), 19 March 19 2025, retieved from: https://www.armscontrol.org/issue-briefs/2025-03/art-new-iranian-nuclear-deal-2025#:~:text=Snapback%20expires%20in%20October%202025%20as%20part,2231%2C%20which%20endorsed%20the%202015%20nuclear%20deal.
[xi] Tasnim News Agency (2025). “US Must Compensate Iran Before Nuclear Talks Resume: Araqchi”, 31 July 2025, retrieved from: https://www.tasnimnews.com/en/news/2025/07/31/3366135/us-must-compensate-iran-before-nuclear-talks-resume-araqchi.
[xii] Le Monde (2025). “Iranian Foreign Minister Abbas Araghchi: ‘It must be guaranteed that in the future, during negotiations, the US does not launch a military attack”, 10 July 2025, retrieved from: https://www.lemonde.fr/en/international/article/2025/07/10/iranian-foreign-minister-abbas-araghchi-it-must-be-guaranteed-that-in-the-future-during-negotiations-the-us-does-not-launch-a-military-attack_6743246_4.html.
[xiii] Reuters (2025). “Iran and Europeans hold ‘frank’ nuclear talks with UN sanctions looming”, 25 July 2025, retrieved from:
https://www.reuters.com/world/middle-east/iran-europeans-hold-frank-nuclear-talks-with-un-sanctions-looming-2025-07-25/.
[xiv] Al Jazeera (2025). “France, Germany and UK say they are ready to reimpose Iran sanctions”, 13 August 2025, retrieved from: https://www.aljazeera.com/news/2025/8/13/france-germany-and-uk-say-they-are-ready-to-reimpose-iran-sanctions.
[xv] Iran Press (2025). “IAEA Deputy Director General Leaves Tehran After Talks”, 11 August 2025, retrieved from: https://iranpress.com/content/308886/iaea-deputy-director-general-leaves-tehran-after-talks.
[xvi]IRNA (2025). “Iran warns it may withdraw from N.P.T. if U.N. sanctions are reinstated”, 12 June 2025, retrieved from: https://en.irna.ir/news/85859600/Iran-warns-it-may-withdraw-from-N-P-T-if-U-N-sanctions-are.
[xvii] Zarif, M.J. (2025). “The Time for a Paradigm Shift Is Now”, Foreign Policy, 15 August 2025, retrieved from: https://foreignpolicy.com/2025/08/15/javad-zarif-iran-diplomacy-war-united-states/.

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