In May 2018, the United States (US) revoked its agreement to the Joint Comprehensive Plan of Action (JCPOA) and breached its commitments by activating a wide range of sanctions against Iran. While claiming to want to contain Iran in the Middle East, the sweeping nature of Washington’s rhetoric and actions since 2018 suggests that its aim is more akin to regime change.[1] Official US reasons for withdrawal include the narrow scope of the JCPOA, which does not cover Iran’s regional proxy forces or missile programme, as well as the expiration dates of some of its provisions, which it alleges are too favourable to Iran.[2] Unofficially, the foreign policy preferences of US allies Israel and Saudi Arabia have been influential factors, as has been the JCPOA’s status as a foreign policy success of the Obama administration. Such reasons being as they may, Tehran was in full compliance with its JCPOA obligations between 2015 and 2019, as was certified time and again by the International Atomic Energy Agency (IAEA).[3]

By withdrawing from the JCPOA, the US broke the commitments it had entered into, ditched a major European diplomatic achievement that sought to bring more stability to a conflict-rich region, and squandered part of its international credibility (‘pacta sunt servanda’). From roughly May 2018 to May 2019, Iran remained in full compliance with the JCPOA based on a logic of ‘strategic patience’ to see whether the EU, Russia and China could keep the deal alive in a meaningful economic sense.[4] When the actions of these entities fell short of Tehran’s expectations and the US terminated the sanction waivers it had extended to Tehran’s major oil-importing customers,[5] Iran took a series of small steps away from the deal and started demonstrating its regional ‘harassment capabilities’.[6] This developed into a tit-for-tat cycle of incidents that included the attack on the Saudi petrochemical complex at Abqaiq and the assassination of general Soleimani. Today, the US strategy of ‘maximum pressure’ has not (yet) achieved its objective, but rather tanked Iran’s economy, causing its government to dig in and increasing regional instability. Its high-stakes gamble of realising geopolitical benefits through economic coercion continues.

It is with this context in mind that the paper assesses the consequences resulting from the interaction between US sanctions on Iran and continental Europe’s own engagement with the JCPOA.[7] In particular, it examines whether the case of the JCPOA is a harbinger of a growing US–European foreign policy gap. As the story of the nuclear deal remains unfinished, the paper seeks to distill lessons relevant for tomorrow’s policies. The JCPOA is on lifeline support, but it is not dead yet. What makes such an assessment difficult is the fact that the US breach of its JCPOA commitments present(ed)(s) the European Union (EU; especially the E3 – Germany, France and the UK) with a triple crisis:

First, the US move is part of a broader crisis in the transatlantic relationship(s). The Trump administration has forced many European countries, including the EU itself, to start repaying with interest the cost of decades of benefiting from the US political-security umbrella. While this umbrella used to be mutually beneficial, today the EU is finding out that it has limited strategic autonomy when its foreign policy interests clash headlong with those of Washington.

Second, the JCPOA makes the longstanding EU ‘foreign policy crisis’ more acute. The EU was never designed to enact a coherent all-weather foreign policy commensurate with its size. Improvements – such as the European External Action Service (EEAS) – have always been incremental. Yet, the last decade features growing great power competition that puts a premium on the ability to conduct an assertive and coherent foreign policy.

Third, there is the EU crisis of confidence with Iran. Due to the inability of the EU and E3 to devise meaningful, timely and US sanction-proof alternatives for economic engagement with Iran, they basically failed to uphold their end of the bargain. The EU and E3 were engaged to facilitate the meaningful reintegration of Iran in the world economy, in exchange for which Tehran accepted (temporary) limitations on the development of its nuclear capabilities. Today, a shorter breakout time, a greater proliferation risk and growing regional tensions are the main results of this crisis.

It is with this triple-crisis in mind that the consequences of the US sanction regime against Iran for the geopolitical role of continental Europe must be considered. In terms of the structure of the paper, Section 2 examines strategic changes in the Middle East between 2011 and 2019 with the aim of situating the JCPOA within the broader geopolitical equation. Next, Section 3 analyses EU policy objectives for the JCPOA, while Section 4 offers a critical self-assessment of EU performance in respect of JCPOA implementation. Subsequently, Section 5 examines the different dimensions of the triple crisis outlined above since they have each acted as a constraint on EU policy performance. Section 6 brings the preceding sections together in a discussion of their geopolitical consequences for Europe. To conclude, Section 7 offers reflections and recommendations for EU policy going forward.

See: link (accessed 22 September 2020).
Joint Comprehensive Plan of Action (JCPOA), Vienna, 14 July 2015, online; UN Security Council, S/RES/2231 (2015), 20 July 2015, online; IAEA verifications and monitoring reports from 2015 to 2020 can be found online (accessed 13 June 2020).
The essential quid pro quo of the JCPOA was regularisation of Iran’s international relations and its integration into the global economy in exchange for its verifiable commitment not to produce nuclear weapons by accepting time-limited constraints on the development of its nuclear capabilities.
See Reuters, 22 April 2019, online (accessed 5 June 2020).
Iran’s steps away from the JCPOA are documented here: ICG, The Iran Nuclear Deal at Four: A Requiem?, Brussels: ICG, 2020.