Fully appreciating the EU/E3’s engagement with the JCPOA requires a brief examination of the different aspects of the EU’s ‘triple crisis’ that have made it difficult to deliver on its political commitment to the nuclear deal. These aspects include growing policy divergences across the Atlantic, the permanent adolescence of EU foreign policy and the crisis of confidence between Iran and the EU.

Starting with growing policy divergences between the US and EU, it is worth noting that these are limited both in terms of scope and in terms of which European countries are affected by them. Scope-wise, there is much the US and Europe continue to agree on at the level of values underpinning democracies, the rule of law, and the role of free markets across the globe. Policy differences related to China, Russia, Israel and Iran always existed, but have been thrown into sharper relief due to the more uncompromising stance of the Trump administration and its limited efforts to build a more united Western policy approach. What has caused additional and serious tension is that the current US administration has massively disengaged from multilateral institutions such as the World Trade Organisation (WTO), World Health Organisaion (WHO), United Nations (UN) and the United Nations Educational Scientific and Cultural Organisation (UNESCO), ditched the Paris climate agreement, sanctioned its European allies (Nordstream), advocated for its tech giants that enable notable misinformation campaigns in foreign political systems, and threatened a trade war with the EU, among other things. US foreign policy has become more go-it-alone, and its definition of its national interests has narrowed. For Europe, the ‘crisis’ results from the corresponding downgrade from junior partner to note-taker while being treated more explicitly as adversary and exposed to economic coercion on selected issues such as trade and the nuclear deal. There is no reason why this medicine would not be repeated in other dimensions of foreign policy since the cost to Washington has so far been limited.

Yet, at the same time, EU members such as Poland and the Baltic states remain strongly oriented towards the US since they see Washington as key security guarantor against any Russian assertiveness of the kind witnessed in the Ukraine and the Baltic area.[37] These EU members have been neither diplomatically nor economically affected by JCPOA developments and happily take a US policy lead on Iran, which became clear when Poland hosted a US-instigated conference on 13–14 February 2019 to address ‘peace and security in the Middle East’.[38] Not a single senior western European politician attended, although some junior officials did go. The US has naturally used these divisions within the EU to its advantage and prevented the emergence of a stronger front to maintain European commitment to the JCPOA.[39]

Regarding the JCPOA, transatlantic policy differences are most profound between France, Germany, the UK, Italy (initially) and the Netherlands on the one hand, and the US on the other. However, even within this group there are major differences. The UK, the Netherlands and Germany share a strong transatlantic security orientation that is deeply anchored among their foreign policy decision-making elites. It is strengthened by factors particular to each country. The UK is the most straightforward case since, as a result of Brexit, it now needs the US more than ever. London is unlikely to burn much diplomatic credit in Washington on Tehran’s behalf. For its part, the Netherlands is a small country with a middle-of-the-road foreign policy. It is unlikely to pick a serious fight with the US given its commercial interests and tendency to refrain from bold foreign policy steps. Finally, Germany still lacks a robust foreign policy debate. For example, interviews conducted for this paper suggest that the extraterritorial sanctions against the Russian-German Nordstream project triggered little strategic debate in the Bundestag. Furthermore, the Netherlands and Germany have in common that they lack a strategic security culture capable of mobilising their entire foreign policy toolkit in pursuit of clearly defined national interests. They tend to get along by muddling through their foreign policy dilemmas, as far as possible keeping friendly with all sides.

Hence, out of these four EU Member States, only France has a foreign policy tradition and the political inclination to go against the US if it feels the situation warrants it. But while Paris has been creative with its ‘Macron-plan’[40] and invested the most political capital of the E3, it has also been cautious with a view to its broader interests in the Persian Gulf region. These include domestic employment generated through arms sales, good relations with the Arab littoral states, and the broader bromance between Paris and Abu Dhabi that is on full display in Libya.[41]

Turning to the next ‘crisis – the permanent adolescence of EU foreign policy[42] – it is useful to note that the EU has made significant political and administrative strides since the 1990s, from an essentially minimalist intergovernmental foreign policy process to developing a decent bureaucratic foundation (the EEAS), some rationalisation of decision-making (limited qualified majority voting (QMV) and committee integration across pillars), and the introduction of new capabilities (like the EU Military Staff and High Representative). Yet, from an external viewpoint, EU foreign policy remains a hybrid that has the best chance of working when national and Brussels institutional interests align in matters of ‘low politics’, i.e. unrelated to (inter)national security. Paralysis of EU foreign policy always lurks around the corner due to the diversity of Member State interests as well as limited EU institutional prerogatives and capabilities. In other words, once the US turned confrontational on the JCPOA, securitised it and leveraged divisions within the EU, it became unrealistic to expect a meaningful EU response despite its High Representative and the E3 having played a significant role in JCPOA realisation. The EU’s inability to back up its commitments when Washington transformed an issue of nuclear non-proliferation into a regional contestation for power was mostly a reminder of the EU’s limited ability to engage in adverse situations of ‘high politics’.

Finally, the JCPOA’s crisis of confidence between the EU and Iran has two main aspects. One aspect has been discussed in detail above and amounts to the inability of the EU/E3 to counter the US strategy of undermining EU official policy by leveraging the exposure of Europe’s private sector to its US investments and the continent’s interwovenness with the dollar-dominated global financial architecture. The other aspect relates to the negative view of Iran among western European opinion- and decision-makers that makes it politically expensive to be seen to act ‘in Tehran’s favour’. To begin with, there is a remarkable lack of insight in Europe into the complex ecology of agenda-setting, influencing and decision-making in Iran, not to mention Iranian society.[43] Beyond a handful of European foreign policy experts, quite a few of its politicians and journalists could do with a masterclass or two on the political economy of Iran. This problem is compounded by the relative scarcity of reliable political, social and research relationships between Iran and Europe that can contribute decent quality analysis and insight. The consequence is that domestic political debate in Europe is sensitive to framing by better-established US and Israeli sources, such as regular parliamentary visits, military exchanges and think tank connections. To make a negative perception of Iran worse, there is also the reality that Iran appears to undertake hostile acts on European territory, such as the recently suspected assassination attempt of a dissident in the Dutch city of Leeuwarden,[44] has a poor human rights record, and remains an autocracy with democratic elements. It is worth adding that adverse perceptions of Iran are aggravated in the US by historically negative framing and an implicit assumption that Iran stopped developing after its 1979 revolution.[45] This is most visible in the form of a bubble of Washington-based poor quality and partisan Iran ‘analysis’.[46]

Based on the preceding analysis, interviews conducted for this paper, and JCPOA policy tracing since 2018 (see Annex), a provisional assessment can be offered of EU/E3 performance in Europe’s ‘triple crisis’:

Table 2
A provisional assessment of European performance against the JCPOA

JCPOA crisis dimensions


Recent measures

Current status

(1) Growing transatlantic policy differences

Most EU countries remain highly dependent on NATO (US dominated) for their security

Growing rifts in the EU-US relationship in terms of trade (WTO), diplomacy (Iran, Russia, Israel, China) and climate (Paris)

The European and US financial architectures are interwoven, but only the US has the will and means to leverage this (JCPOA, )

Modest increase in and moderate progress in

Strong trade pushback against Washington resulting in a ‘’

EU, China and 14 other countries create a

EU transposed the Paris agreement into its ‘’

No meaningful pushback against US foreign policy on Iran or Israel; Macron initiative towards Russia; and a more nuanced EU approach to China

No progress/action to increase EU economic autonomy[47]

The EU is not able to counter US pressure on foreign policy issues of ‘high politics’ where US intensity preferences are high and the EU is divided, or its interests are not greatly affected

The EU continues to lack an autonomous military capability

(2) An unfinished European foreign policy

Foreign policy orientations and priorities among EU Member States vary significantly

Despite the EEAS, the EU retains several foreign policy centres with some autonomy (DG NEAR, Council, ECHO, DG DEVCO)

EEAS has limited capabilities

Financial instruments are not strategically controlled by the EEAS (e.g. European Development Fund)

There is talk but no momentum to introduce QMV in European foreign policy decision-making[48]

Internal coordination within EU institutions has improved, but remains cumbersome due to different mandates[49]

The EEAS has grown, but remains , with 4,100 staff

European Defence cooperation progresses, but pooled military capabilities remain absent

The EU does not currently possess the unity of strategic thought, culture, organisational cohesion and instruments to enact a foreign policy commensurate with its size and interest

EU foreign policy remains a hybrid of pooled and national elements. Success requires strong Member States to support particular initiatives

(3) Upholding the letter and spirit of JCPOA

The European private sector makes autonomous decisions on investment and trade

The interwovenness of US-European financial and investment markets gives US sanctions a real impact on large European businesses; extraterritoriality extends this effect to medium-sized businesses via the financial sector

European governments have not been willing to go against the US in a tangible manner beyond political symbolism

The blocking statute was re-enacted to reduce the extraterritoriality of US sanctions in the EU

INSTEX was created to reduce the sanctions risk of trading with Iran

The European Commission encouraged the EIB to support and in Iran

The Macron plan of a temporary credit line for Iranian oil sales was conceived in France, but made dependent on US agreement

The blocking statute is ineffective for MNEs with business in US and EU markets, and does not counter the ‘chilling effect’ of sanctions

The slow creation and narrowing scope of INSTEX turned it into a symbolic act of resistance

The EIB could not risk its business model

The EU did not pursue the Macron initiative via its own Treasuries and state-owned banks

The EU and E3 refused to support extension of the arms embargo on Iran and disagreed with US claims to have authority under the JCPOA to trigger UN ‘snap back’ sanctions[50]

In brief, the EU’s ‘triple crisis’ created a cascade of limitations on its ability to deliver against the JCPOA. Seen in this light, its policy actions have in fact been fairly audacious because they depart clearly from US policy (especially INSTEX). However, the persistence with which the EU/E3 has sought to maintain dialogue with the US and the slow evolution of its own policy interventions regarding JCPOA have been based on the mistaken premises that there was a dialogue to be had with Washington and that it would tolerate a measure of practical support for Iran.

From an Iranian perspective, EU/E3 policy actions are symbolically relevant insofar as they enable it to isolate the US internationally. Practically, they are irrelevant. The growing expression of European unease with Iran’s regional profile adds insult to injury in Tehran because it views most of its actions as triggered by prior US aggression – which, in its view, benefits from latent European support. The net effect of EU/E3 engagement has been that its original objectives – non-proliferation and confidence building – are disappearing beyond the horizon.

For example, Russia has turned Kaliningrad into a forward military bastion replete with offensive, non-strategic nuclear capable missiles and regularly violates the airspace of its Nordic and Baltic neighbours. See: Westerlund, F., Russia’s military strategy and force structure in Kaliningrad, FOI (Swedish Defence Research Agency), online, 2017.
See: link (accessed 26 June 2020).
In turn, the EU also features more Russia-friendly EU members, such as Hungary and Italy, which Poland and the Baltic states have to contend with.
It proposed to offer Iran a time-limited credit line for oil sales in exchange for a return to negotiations and JCPOA compliance (August 2019).
Saudi Arabia and the UAE were the second and sixth biggest buyers of French arms between 2008 and 2017. France also participates in regular military exercises in Qatar, Saudi Arabia, Kuwait and the Emirates. See: France24, online, 20 April 2019; Gulf Times, online, 13 November 2018; Arab News, online, 10 October 2017, Peninsula Qatar, online, 5 May 2019. Also: Wezeman, P. et al., Trends in international arms transfers, 2019, Stockholm: SIPRI, 2020.
This is a longstanding issue that has been discussed at length elsewhere: Tsoukalis, L., What kind of Europe?, Oxford: OUP, 2005; Van Middelaar, L. De passage naar Europa: Geschiedenis van een begin, Historische Uitgeverij, 2009; Tonra, B. and T. Christiansen (eds.), Rethinking European foreign policy, Manchester: MUP, 2018.
Although there are accessible analyses readily at hand: Geranmayeh, E., Reviving the revolutionaries: How Trump’s maximum pressure strategy is shifting Iran’s domestic politics, ECFR, online, 2020; Brumberg and Farhi (eds.) (2009), op.cit.; Leverett and Leverett (2013), op.cit.
See: link (accessed 2 July 2020). None of these incidents are fully linked to Iran but the Dutch government says it has strong indications from its intelligence service (AIVD) that (parts of) the Iranian government is involved.
See: Bajoghli, N., ‘American Media on Iran: Hostage to a Worldview’, in: Anthropology Now, 11:3, 31-38, 2019.
A brief check of the twitter feed of, for example, Mark Dubowitz (@mdubowitz) regarding Iran by anyone with a bit of knowledge of the country quickly exposes advocacy dressed up as analysis.
For some ideas on how greater European economic autonomy can be achieved: Leonard et al. (2019), op.cit.
Schuette, L., Should the EU make foreign policy decisions by majority voting?, CER, online, 2019.
See for example the mission letter from European Commission President Von der Leyen to the High Representative/VP of the European Commission Borrell Fontelles that spells out his duties of coordination, but much less his authorities (online).
ICG, Iran: The U.S. Brings Maximum Pressure to the UN, Brussels: ICG, 2020, online; Adebahr, C., Trump’s ‘virtual reality’ foreign policy, Politico, 2020, online.