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date: 22 October 2019

Iran and European Union Politics

Summary and Keywords

The Islamic Republic of Iran and the European Union (EU) have not yet established formal diplomatic relations, but since 1979 the Union and its member states have had various strong if often conflictual interactions. The relationship has been marked by distinct phases that reflect the emerging character of the partners, a theocratic republic on the one hand and a Union of interdependent democratic states on the other. While mutual economic interests have formed the basis for substantial interactions, relations with member states and the EU itself have been colored by a long and sometimes hurtful history of European states’ role in Iranian politics, including the Russian and British imperial influence over Persia in the late 19th and early 20th century, the British (and American) involvement in the coup against democratically elected Prime Minister Mohammad Mosaddeq in 1953, and the French hosting of Ayatollah Ruhollah Khomeini, an avowed critic of the Pahlavi dynasty, prior to the anti-authoritarian revolution in 1979. Over time, the relationship has substantially shaped the character and direction of the politics of the EU’s common foreign and security policy, resulting in more policy coherence between member states and the EU, more policy autonomy, particularly vis-á-vis the United States, and more proactive behavior, such as during the nuclear negotiations leading to the Joint Comprehensive Plan of Action (in 2015). By engaging with a problematic member of the nonproliferation treaty, the EU not only specified and thus strengthened the treaty, but it also grew into an international nonproliferation actor to reckon with.

Keywords: Iran, European Union, European Union politics, EU external relations, nonproliferation, WMD strategy, sanctions, terrorism, United States, Israel


The Islamic Republic of Iran and the European Union (EU) have not yet established diplomatic relations. But the EU and the growing number of its member states have had various strong but often also contentious interactions for decades. Since 1979, when massive popular protests resulted in the demise of the longstanding, autocratic rule of Mohammed Reza Shah Pahlavi, the relationship has been marked by three distinct phases that reflect the diverging character of the partners: a theocratic republic on the one hand and a union of interdependent democratic states on the other. Mutual economic interests have formed the base for substantial interactions: the EU member states’ demand for oil and gas and Iran’s need for advanced industrial technology and infrastructure. But historical legacies (i.e., the sometimes hurtful history of European states’ active influence in Persian and Iranian politics, economics, and culture) and the growing gap between an emerging theocratic republic and a union of interdependent democratic states have reshaped the politics of the EU’s policies toward Iran.

Various scholars note that EU member states have pursued distinct Iran policies, often diverging strongly from each other as well as from the United States’ course of action. In particular, European governments have been concerned to a variant degree with Tehran’s revolutionary policies in the Middle East and beyond: the Islamic Republic’s deplorable human rights record, including the killing of Iranian opposition leaders in European countries and the fatwa against the British author Salman Rushdie; the active support of Islamic political groups in the Middle East, including militant organizations such as Hezbollah; and the active opposition to the Israeli-Palestinian Peace Process, including the denial of the right to existence for the state of Israel. Since 2002, however, after undeclared nuclear activities were revealed by an Iranian opposition group (see the section “Conflict Over Iran’s Nuclear Program”), respective national Iran policies have converged considerably, informing an emerging common EU nonproliferation policy vis-à-vis Iran.

The scholarly literature specifically on Iran–EU relations is substantial but checkered: There is no comprehensive account of the relationship since 1979 that covers both the Iranian and EU policy processes as well as the various policy areas. On the Iranian perspective Moshaver (2005), Rakel (2008), and Mousavian (2008) provide comprehensive historically informed analyses that stress—implicitly or explicitly—differences between reformist or conservative factions in the Iranian policy establishment and society. In turn, the evolution of the EU’s Iran policy before 2002 is covered in Halliday (1998), Tarock (1999), and Kamel (2015), focusing on the divergent reactions by France, the United Kingdom, and Germany toward the revolutionary regime before 1992 and the policy conflict over the EU’s “critical dialogue” with Tehran thereafter.

In comparison, the extant literature on the politics within the EU during the so-called Iranian nuclear crisis (since 2002) is extensive and (mostly) theory-driven. This is true for the EU as an emerging and effective actor in the areas of nuclear nonproliferation (Alcaro & Tabrizi, 2014; Bergenäs, 2010; Cronberg, 2017a, 2017b; Dee, 2015; Denza, 2005; Dryburgh, 2008; Harnisch, 2019; Hertwig, 2012; Kile, 2005; Meier, 2013; Portela, 2003; Santoro, 2016; Smeland, 2004; Sperling, 2015), coercive diplomacy (Sauer, 2008, 2015), or the international sanctions regime vis-à-vis Iran (Boogaerts, 2018; Onderco, 2015; Portela, 2015; Seeberg, 2016). But this also pertains to specific EU institutions (Cronberg, 2017b), particularly the High Representative for Foreign and Security Policy and the incipient European External Action Service (Adebahr, 2017; Alcaro, 2018; Hill, 2011; Zanon, 2012), and albeit to a lesser degree, to the Council, the Parliament, and EU member states (Fabius, 2016; Harnisch, 2007; Santini, 2010; Schmitt, 2017; Seaboyer & Thränert, 2007).

Based on the actorness approach (Jupille & Caporaso, 1998) or role theory (Elgström & Smith, 2006), these studies find that the EU performed various different roles over the course of the crisis, gaining effective actorness in the field of nonproliferation as well as the international sanctions regime, thereby facilitating (but not causing) the Joint Comprehensive Plan of Action (JCPOA) between Iran, the P5, and Germany. While differing on the relative impact, most studies agree that the EU’s thrust toward “effective multilateralism” emerged because the United States–led Iraq intervention in 2003 had left the majority of member states disillusioned behind and because Iran and other significant powers ascribed the EU a mediator role (Adebahr, 2017; Alcaro, 2018; Cronberg, 2017a, 2017b; Harnisch, 2019; Sauer, 2019). In a similar vein, the analyses on the EU’s sanction regime for Iran suggest that while commercial interests did play a role for some members, the growing policy coherence may only be explained when taking into account the respective importance of the relationship with the United States (and Israel). As Boogaerts (2018) argues, the growing coherence of the tailor-made EU sanctions regime for Iran in combination with the Rouhani administration’s conviction to unleash Iran’s economic potential in 2013 contributed substantially to the breakthrough in the negotiations in 2014 and 2015 (see also Onderco, 2015).

Against this background, this article takes a guarded actorness approach, broadly asking how the interaction with Iran shaped the EU’s policy capacity and coherence to act in various policy areas of this bilateral relationship. In doing so, it focuses on the interaction between member states’ policies and the (gradual) evolution of common EU positions, and it asks how and how far the politics of the EU’s Iran policy can be traced back to the relations with the United States and the internal institutional dynamics of the EU. Thus, the following analysis foregrounds the politics of the EU–Iran relationship rather than providing a comprehensive theory-driven account of EU–Iran relations in general.

Historical Ties Between the Islamic Republic of Iran, the EU, and Its Member States

During much of the first decade after the revolution in 1979, the European Community’s (EC) relations with the Iranian regime were dominated by its bigger member states. After the U.S. hostage crisis in Tehran (1979–1980), the EC followed the U.S. arms embargo vis-à-vis Iran and the “neutrality policy” in the Iran-Iraq war (1980–1988), even if some EC member states traded arms with warring parties (see the section on Economic Relations With Iran Prior to 2003: The Politics Within the EU). Under the revolutionary leadership of Ayatollah Khomeini, the Islamic Republic pursued a “Neither-East-Nor-West Policy,” combining a fervent anti-Americanism with support of Islamic groups in the region. In addition, as Shia clerics tried to establish and stabilize the first Islamic theocracy in modern times, their revolutionary zeal informed a policy of “state-sponsored terrorism” (Hoffman, 1990), starting to kill members of the Iranian opposition in European states as well as taking Western hostages in the region (Moshaver, 2005). Most EC member states thus kept their distance from Iran, preferring friendly relations with Arab states that were crucial for oil supplies and market access.

As a former colonial power with involvement in the coup d’etat against Prime Minister Mossadeq, the United Kingdom’s Iran policy in the 1980s has been presented as a trade-off between transatlantic solidarity, Britain’s commercial interests, and its principled stance on human rights. It follows that Britain sought exemptions from the embargo for those services most profitable, such as engineering consultancy, insurance, transport, and tourism (Rakel, 2008). However, London’s guarded approach experienced a major rupture in February 1989 when Ayatollah Khomeini issued a fatwa against Salman Rushdie, the British author of The Satanic Verses. Not only did the Iranian parliament, the majlis, threaten to severe diplomatic relations if existing copies were not confiscated and the book’s further publication banned, but the Iranian regime did also indicate that although the government would not enforce the fatwa by killing the author, private actors were free to do so without governmental support. Iranian–United Kingdom relations improved markedly only after the moderate Iranian President Kathami had declared the affair “completely finished” in a speech before the United Nations (UN) General Assembly in 1998 (Tarock, 1999, p. 59).

In 1980, France’s relations with Tehran were set to be strong because the French government had allowed Ayatollah Khomeini to take residence near Paris after the Iraqi government had expelled him on the request of the Shah. But cordial relations soon turned sour when the Socialist government under Francois Mitterand gave political asylum to various opponents of the Islamic regime, including former President Banisadr, and Paris continued to supply advanced military equipment to Saddam Hussein’s regime in Iraq. By the mid-1980s, relations had deteriorated to a degree that French citizens could not leave Iran, and Islamic militias with close ties to Iran kidnapped French diplomats in Beirut. After a French navy vessel was attacked by an Iranian vessel in the summer of 1987, the French navy threatened to take retaliatory action against the Iranian navy if it attacked again and suspended diplomatic relations in late July. Subsequently, the relations were restored a year later when Iran—after ending hostilities with Iraq—facilitated the release of French hostages in Lebanon, thereby sending an early signal of a potential reversal in its revolutionary foreign policy (Tarock, 1999).

Among the big European powers, Germany arguably held the closest ties during the 1980s with Iran, building upon the successful mediation effort for the hostages in the U.S. embassy in 1979–1980 (Bösch, 2015). Without any military involvement or colonial baggage, Germany soon became the biggest European exporter of goods and services to Iran, including (temporally) a major construction project for two nuclear power plants near Bushehr that had started under the shah regime in 1975. Adhering to a somewhat strict(er) neutrality during the Iran-Iraq war, German Foreign Minister Genscher held political talks in Tehran in 1985. Then, immediately after the ceasefire agreement between Bagdad and Tehran, Germany became the primary promoter of a “critical dialogue” with the Iranian government, which, in the beginning, included sensitive issues such as human rights and German hostages held in Lebanon (Kamel, 2015; Mousavian, 2008). However, Germany was unable to influence Iran’s human rights record substantially, which had come under intense scrutiny in Germany and the EU. German–Iranian relations took a decisive negative turn after a German court in 1997 found that four Iranian-Kurdish opposition leaders were killed in a Berlin restaurant in 1992 (Mykonos Affair) and that the assassination was ordered by a special operations committee, including Iran’s supreme leader Ayatollah Khameini, President Rafsanjani, and the head of the Iranian Foreign Intelligence Service, Ali Fallahi (Tarock, 1999). As a consequence, the German side suspended the critical dialogue and recalled its ambassador from Tehran, indicating a major policy reassessment.

In sum, in this early period the politics of the EC’s policies vis-à-vis Iran amounted to what has been called “composite foreign policy” or “zusammengesetzte Außenpolitik” (Rummel, 1982). Among the bigger EC member states, France and the United Kingdom maintained substantial economic, political, and cultural relations with Iran, which turned more contentious over Iran’s aggressive use of taking Western hostages and issuing fatwas as a diplomatic tool. In contrast, Germany (and Italy) enjoyed more stable, even if restrained, relationships during the Iran-Iraq war. Thus while national Iran policies prevailed in general, EC member states coordinated their behavior in some policy areas—such as common trade policy—that had a bearing on their overall strategic objectives (Allen, 1982). Notably, when the EC decided in April 1980 on the package of sanctions for Iran, some member states were skeptical about the effects, arguing that they supported them only due to their close ties to the United States (Gerschoffer, 1998). In comparison, by the late 1980s, western European government officials started to mention aggressive Iranian behavior toward their peer EC member states citizens (e.g., Salman Rushdie) as the primary reason for a more coherent EC stance, thereby indicating that fellow European citizens had become “significant others” when interacting with third parties like Iran.

Political Relations With Iran Prior to 2003: The Politics Within the EU

With the European Political Cooperation of the European Community turning into the Common Foreign and Security Policy of the European Union at the summit in Maastricht (December 1991), the Council announced its first consistent and unified European policy toward Iran at a Council meeting in Edinburgh (December 1992): a “critical dialogue” of the EU with the regime in Tehran (European Council, 1992, §15–17), which superseded Germany’s earlier initiative. The dialogue format became possible through a substantial moderation of the revolutionary zeal in foreign affairs under the new president Hassan Rafsanjani. But, importantly, the specific form and content of the critical dialogue clearly reflected a new and persistent pattern of policy cooperation among EU institutions and member states (Struwe, 1998).

Lacking mutual diplomatic recognition, the form of a “critical dialogue” indicated both the potential for a future regular “political dialogue” while foregrounding the outstanding conflicts over Iran’s lacking compliance with international norms and standards, most notably extra-legal killings and death threats. At the same time, the dialogue sought a multilateral engagement of Tehran, stressing civilian instruments to strengthen “moderate politicians” instead of emboldening religious radicals by punitive measures (Kaussler, 2012; Moshaver, 2005).

Procedurally, the dialogue involved biannual meetings of the EU troika with senior officials of Iran’s foreign ministry. Reflecting common dispositions rather than a strong consensus among member states, EU officials pursued a diffuse linkage strategy, tying a further improvement of relations to changes in Iranian behavior (such as support of terrorist activities). In turn, this loose coordination allowed member governments’ wide latitude to pursue national political and economic initiatives vis-à-vis Tehran (Calabrese, 2004).

The critical dialogue also established a new internal policy process between EU institutions and member states, as it involved a coordination of both EU institutions’ and member states’ policies. The Council of Ministers would communicate its concerns through confidential démarches and public declarations as well as through regular bilateral meetings of the Troika with their Iranian counterparts, supporting bilateral and multilateral initiatives of member states to change Iranian behavior (e.g., the lifting of the fatwa against Salman Rushdie). The EU Commission used these instruments by raising human rights (and other) concerns during regular meetings with Iranian officials. In turn, the EU Parliament would check on both Commission and Council policies, publicly challenging Iranian human rights abuses through resolutions, critical hearings, and other actions, such as sponsoring resolutions in the UN Commission on Human Rights and UN General Assembly (Struwe, 1998).

The critical dialogue of the EU ended after five years of constant criticism from the United States and growing public scrutiny in early 1997 when a German court found direct involvement of the Iranian political leadership in killing of dissidents in a Berlin restaurant in September 1992 (Mykonos Affair). Subsequently, the European Council subsequently stressed that this Iranian behavior was “totally unacceptable in the conduct of international affairs” and that “no progress [could be made, S.H.] while Iran flouts international norms, and indulges in acts of terrorism” (EU Presidency, 1997). Notably, only one EU member state, Denmark, had ended the “critical dialogue” on a bilateral basis already in August 1996, arguing that the bilateral talks with Tehran had shown no results while keeping up with the format on the EU level (Struwe, 1998).

The (temporary) solidarity on the critical dialogue within the EU is all the more noteworthy because the United States actively tried to press European states to isolate Iran (during the ongoing dialogue phase). For example, in 1993, the Clinton administration decided to implement a policy of “dual containment” vis-a-vis Iran and Iraq, seeking to severe economic ties between Iran and the international community, including loans from the World Bank and IMF, citing Iran`s state sponsorship of terrorism, gross human rights violations, and pursuit of weapons of mass destruction (WMD; Kaussler, 2012).

The transatlantic split on Iran came to a head in 1996 when the Republican-dominated House of Representative introduced what became known as the Iran-Libya Sanctions Act, establishing a U.S. policy of “secondary sanctions,” penalizing U.S. and foreign trading companies that invested more than US$ 40 Million in Iran by boycotting its imports and denying it government contracts and commercial loans. The EU and its member states rejected these measures (and those under the Helms Burton Act against Cuba), contesting Washington’s authority under international law to impose “extraterritorial” measures on European companies. Subsequently, the EU (and its member states) initiated a dispute settlement procedure within the World Trade Organization and established an EU blocking statute, prohibiting European companies to abide by U.S. sanctions and threatening the imposition of countersanctions against U.S. interests and assets under European jurisdiction (Genard, 2014). Agreeing to disagree, the EU and U.S. administration reached a mutual understanding in 1997 that allowed President Clinton to exempt European companies from U.S. sanctions (Genard, 2014.).

Solidarity among the EU member states in the face of Washington’s extraterritorial claims did not, however, translate into a European solidarity vis-à-vis Iran’s aggressive behavior. In the aftermath of the Mykonos Affair, most European states withdrew their ambassadors from Tehran, but Greece did not. Moreover, a group of states, including France, Austria, and Italy, challenged the common position, demanding a quick return to diplomatic relations while Germany, Denmark, the Netherlands, and Sweden held that the EU should limit its interactions until Iran had changed its behavior. Sensing profit from discord, Iran’s leadership let Germany know that while all other EU ambassadors were welcome, Germany’s was not (Ali, 2018). As the Dutch EU presidency urged all member governments to suspend the return of their ambassadors—so that Iran would not be allowed to punish one member state to be reprimanded for a common policy by all—several member states, Italy, Greece, and France argued that contacts with Iran should be suspended only temporarily (six months) and should not include technical or informal diplomatic meetings (Rudolf, 1999).

Facing incontrovertible evidence of Iranian malfeasance, the divergent interpretations of how critical the dialogue with Iran should be conducted prevented the EU and its member states from acting coherently and consistently. Thus, whereas the Mykonos Affair showed that the EU was indeed capable of responding when concrete evidence of Iranian wrongdoing was presented, the affair’s aftermath demonstrated that national commercial interests soon prevailed over common European positions. As a result, EU politics toward Iran reflected some commonly held positions, various divergent national approaches, and some intergovernmental coordination on political relations and sanction policies until 1997 (Rudolf, 1999).

Following the election of the moderate cleric Mohammed Khatami, who became Iran’s president in June 1997, EU relations with Iran took a decisive turn. After President Kathami had announced a series of reforms, including economic liberalization, a strengthening of the rule of law, the suspension of the fatwa against Salman Rushdie, as well as a “dialogue between civilizations,” the EU and its member states reacted swiftly. Ambassadors returned, trade relations were intensified in the face of U.S. extraterritorial legislation, and the EU Council decided to (re-)engage with Iran on the level of undersecretary of state or deputy minister in a “comprehensive dialogue.”

Coming in the aftermath of the Amsterdam treaty, which created the position of an EU High Representative for Foreign and Security Policy, it is noteworthy that it was the EU Commission that took a proactive stance on developing a new policy framework toward Iran. Navigating between cautious member states raising human rights concerns (Germany, the Netherlands) and a group promoting “normalization” (France, Italy), the Commission devised a three-pronged negotiation structure in early 1998: first, a comprehensive dialogue on a broader range of global (WMD, terrorism), regional (Middle East peace process, Iraq), and bilateral (e.g., drugs and refugees) issues; second, a set of EU-Iran technical working groups (on trade and investment, drugs, refugees); and third, an Iranian-EU Energy Policy Dialogue (Rakel, 2008).

Responding to the 2000 elections of the Iranian parliament, where moderate representatives aligned with President Kathami had won a substantial majority, the EU again shifted gears. In November 2000, the EU Council issued a directive to the Commission to produce a new policy, capable of supporting the reforms in Iran. In turn, the Commission advised the Council to conduct a multifaceted approach, based on the intensification of contacts on all levels (including people-to-people) and, when conditions where right, to negotiate a Trade and Cooperation Agreement (TCA; Calabrese, 2004).

Divergent strategies and tactics reflecting more basic differences between member states reoccurred in the debate over the character of the TCA: a majority group (led by Spain, France, and Italy) favored a simple “community type” trade agreement under EU competence subject to ratification only by the European parliament. A second group (consisting of the Netherlands, Germany, the United Kingdom, Portugal, and Luxemburg) preferred a “mixed agreement,” requiring both EU and national ratification processes and containing a political chapter addressing terrorism and human rights concerns (Rakel, 2008).

Turning once again toward intergovernmentalism, the European Council decided at its summit in Luxembourg (2002) to pursue the mixed and integrative strategy that allowed for separate negotiations of political and economic issues but which also set strict limits for economic benefits for Iran while requiring (national) ratification of political and economic matters in a single package (Calabrese, 2004). The Commission and Council held several meetings with their Iranian counterparts (and some working groups met intermittently until 2005) to conclude a TCA; most notably, the EU also engaged Iran in a series of human rights meetings (December 2002, March and October 2003, June 2004). During these meetings experts with different backgrounds, including NGOs from both the EU and Iran, participated and discussed among other issues the discrimination against women, torture, the death penalty, the accountability and independence of the judiciary, the policy and prison system, as well as freedom of expression. However, the dialogue came to a halt when conservatives gained power in the majlis and the presidency over the course of 2004–2005 (Kjaerum, 2007).

Thus as a consequence of the conservative shift in Iranian domestic politics and the revelations of previously unknown Iranian nuclear activities at sites in Arak and Natanz, the comprehensive dialogue fizzled out and EU member states turned their attention toward the nuclear dossier.

Economic Relations With Iran Prior to 2003: The Politics Within the EU

Arguably, commercial interests of European states played an important if not a decisive role in the EU’s relationship with the revolutionary regime in Tehran. As Kamel (2015) has argued persuasively, the EU and its members acted upon the assumption that stronger economic ties would moderate Iran’s revolutionary zeal as more and more Iranian citizens benefitted from the integration in the world economy. As a consequence, trade and investment with Iran continuously grew since 1979 despite the regime’s repeated human rights abuses, support of terrorist organizations (which also kidnapped European citizens to extort concessions), and the pursuit of WMD (Ali, 2018).

In this context, and despite the growing misgivings about the regime’s human rights record, EU-Iran trade during the Iran-Iraq war grew to such a degree that European states accounted for 41% of all arms exports to Iran between 1985 and 1988 despite an UN arms embargo and despite the fact that some European states also supplied weaponry to the Iranian adversary Iraq (Kamel, 2015, p. 94). While this questionable practice went almost unchallenged during the 1980s, subsequent revelations during the first Gulf War (1991–1992), showing that European arms transfers with dual-use technology had enabled Iraq to produce chemical weapons and develop a nascent nuclear weapons capability, contributed to the substantial harmonization of European arms control policies in the early 1990s, finally resulting in the EU Code of Conduct on Arms Exports, adopted in early 1998 (Bromley & Broszka, 2008).

EU trade relations with Iran intensified considerably in the aftermath of the Iran-Iraq war and the (partial) opening of Iran’s economy under the new President Rafsanjani. Despite the Rushdie affair and further human rights concerns, European states maintained (or quickly reinstated) their diplomatic and commercial relationship with the Islamic Republic. Reflecting both rising concerns about the spread of WMD in the Middle East at the time, and in Iraq in particular, and the European conviction to engage in a critical dialogue with difficult partners, EU member states governments shared “a core consensus that no economic sanctions [vis-à-vis Iran, S.H.] should be applied beyond export controls for dual use technologies” (Rudolf, 1999, p. 74).

Following the opening of the Iranian economy, European trade and investment patterns shifted substantially. This was first due to the development of the Iraqi regime being discredited and, under international supervision, that some European countries who had held commercial interests in Iraq turned toward the critical dialogue with Iran, thereby broadening the number of partner economies for Iran. This diversification in trading partners was in line with President Rafsanjani’s strategy to reduce Iran’s reliance on a few partners and carbon-based export benefits (Kamel, 2015, pp. 103–104).

As a result, the EU and its member states became Iran’s largest trading partner(s) in the mid-1990s. At the time, the EU accounted for over 40% of Iran’s imports while exports to the EU represented 36% of the total Iranian exports. Iran’s trade deficit grew substantially, driving both Iran’s external debt to the EU to US$10 billion by 2001 and leaving the Rafsanjani and Kathami administrations struggling to reduce Iran’s considerable trade deficit with the EU (Moshaver, 2005).

To reduce the dependence on oil exports and the EU as the major trading partner, the Kathami administration engaged with neighboring Islamic countries, most notably Saudi Arabia, in coordinating their respective export policies. Forging such closer ties with Muslim countries was also meant to strengthen Islamic countries’ bargaining position vis-à-vis more advanced but carbon-dependent economies. In this vein, President Kathami sought to and succeeded in negotiating a common position with Saudi Arabia’s leadership to stabilize oil prices through the Organization for Petroleum Exporting Countries.

Iran and European Union PoliticsClick to view larger

Figure 1. EU share in overall Iranian trade 1979–2019.

Source: International Monetary Fund (2019).

As Figure 1 shows, Iranian measures taken by the mid-1990s to reduce the trade deficit with the EU were at least temporarily successful, resulting in a marked improvement of exports to the EU in overall Iranian trade. More noteworthy though is that Iran was able to almost double its trade volume with the EU in the early 2000s, reflecting the EU’s (temporary) willingness to bolster trade and investment relations so as to cater to moderate liberal constituents in the Iranian populace (Kamel, 2015). Thus, while U.S. President Bush named Iran a member of the “axis of evil” in the aftermath of the attacks on September 11, 2001, the EU and its member states intensified their relationship with the Iranian regime even though holding different positions regarding the mechanics of a future TCA. And yet, negotiations on an Iran–EU Trade and Cooperation Agreement stalled in 2003 because of persistent allegations over illicit Iranian nuclear activities (Bergenäs, 2010). As a consequence, EU-Iranian trade relations grew only modestly until 2010, then nosedived and recovered as a percentage of Iran’s overall trade balance only after the settlement for a Joint Plan of Action (JPA) in 2013 (see later discussion).

Conflict Over Iran’s Nuclear Program: The EU as a Nonproliferation Actor

To prevent another crisis about WMD, such as in Iraq, the French, British, and German foreign ministers (E3) embarked on negotiating strict limits on the (civilian) Iranian nuclear program in the summer of 2003. The E3 would soon be joined by the EU High Representative, Javier Solana himself, but even more so his successors, then became the lead negotiator for the permanent members of the UN Security Council (plus Germany) in the negotiations with Iran, thereby turning into the EU3. What is often described as the emergence of the EU as a (serious) nonproliferation actor, bent on putting “effective multilateralism” to work (Cronberg, 2017a), can best be understood as an attempt to respond to a two-fold crisis: a crisis within the EU as diverging member states policies over Iraq threatened to undo the EU’s Common Foreign and Security Policy and a crisis in the international rule-based order because the United States and a coalition of states including EU member states took the initiative into their own hands after failing to solicit a UN Security Council resolution legitimating the use of military force against Iraq’s alleged noncompliant behavior.

Since 2003, the policy process, strategies, and instruments of the Union and its members changed substantially, turning the EU into a coherent, reliable, and purposeful partner, negotiating on behalf of the permanent members of the UN Security Council as well as its member states. So far, an extensive literature has focused on three major research questions: first, whether the EU has been successful in preventing a military escalation (e.g., Kile, 2005; Meier, 2013; Santini, 2010) or only partially successful in not achieving zero nuclear enrichment in Iran (Bolton, 2007; Fitzpatrick, 2011); second, whether the EU was able to act coherently by employing coercive diplomacy economic sanctions and enlisting all of its member states (Boogaerts, 2018; Onderco, 2015; Sauer, 2015), so that the EU could be regarded as a unitary actor rather than a loose assemble of national foreign policies (Adebahr, 2017; Dryburgh, 2008; Sauer, 2007, 2008); and third, to what extent the politics and policies of the EU during the nuclear crisis were caused by internal or external factors (Alcaro, 2018; Ali, 2018).

To discern the roles the EU3 played during the crisis, it is important to grasp that these have varied considerably over time (Harnisch, 2019; Sauer, 2019). During the first phase (2003–2005), the EU3 successfully mustered support from EU member states, after some contestation, and managed to established itself as a (tolerated) interlocutor with the Iranian government. During the second phase, from 2006 to 2012, the EU3, or more precisely the EU High Representative, expanded its role vis-à-vis member states, formally acting on behalf of them and forming a united front on sanctions in 2010. This was further reiterated by pursuing a double-track diplomacy vis-à-vis Tehran concretely on behalf of the P5 (+1) and the broader international community, since the UN Security Council endorsed the EU3 role in several resolutions since 2006. In the third phase, the EU3/EUHR continued to serve as a key mediator, in particular toward China and Russia, while working in tandem with key officials in the Obama administration, which had established a second bilateral negotiating track with the new Iranian administration under President Rouhani in Oman in 2013.

The First Phase, 2003–2005

Iran engaged with the three European foreign ministers in August 2003 only after the United States had invaded the neighboring Iraq and the Bush administration had rejected a comprehensive Iranian proposal, reportedly including the exchange of the recognition of the state of Israel and the suspension of support for terrorist proxies in the Middle East with the normalization of relations with the United States East (Shelala, Fite, & Kasting, 2013). In turn, the U.S. intervention in Iraq and the withdrawal of North Korea from the Nonproliferation Treaty (NPT) were perceived as serious challenges to a rule-based international nonproliferation order, requiring an immediate response (Alcaro, 2018).

The EU addressed these challenges in two meetings of the European Council in April 2003 and the General Affairs and External Relations Council in June (GAERC; Hertwig, 2009), which triggered the development of the Basic Principles for an EU Strategy against Proliferation of Weapons of Mass Destruction (Council of the European Union, 2003b), the adoption of the EU’s WMD strategy in the Declaration of the European Council (Council of the European Union, 2003a), and the first-ever European Security Strategy, titled “A Secure Europe in a Better World” (European External Action Service, 2003), in December 2003.

On Iran, the General Affairs Council expressed “serious concerns” and urged the government in Tehran to unconditionally implement the Additional Protocol, which grants substantial further inspection authority, and fully cooperate with the International Atomic Energy Agency (IAEA). To underline the urgency, the Council suspended negotiations on the TCA. Reflecting earlier differences on the need to engage with Iran, a group of EU member states (among them Austria, Italy, and Spain) held that TCA negotiations should be intensified rather than suspended while France, Germany, and Britain argued in favor of linking progress with the TCA (negotiations) with the nuclear issue (Ali, 2018).

But when the Bush administration pushed for referring the Iranian dossier to the UN Security Council at the IAEA Board of Governors meeting in June 2003, the EU countries resisted in alignment with Russia and China, arguing that the Iranian nuclear issue should be dealt with diplomatically. Consequently, the E3 send a letter to the Iranian leadership in early August 2003, pressing for an end to all fuel cycle activities in addition to fully cooperating with the IAEA and implementing the IAEA Additional Protocol in exchange for possible cooperation on technology.

When Tehran did not respond, the E3 drafted a tough resolution at the next IAEA Board of Governors meeting in September 2003, setting a deadline for October 31, which called for a suspension of all enrichment related activities and a full declaration of all materials and components relevant to its enrichment activities. After Iran had signaled cooperation, the E3 foreign ministers visited Iran on October 21, issuing the so-called Tehran Statement (Joint Statement, 2003). In the agreement, Iran pledged to cooperate fully with the IAEA and resolve all outstanding safeguard issues concerning its nuclear past. Moreover, it would sign the Additional Protocol, begin the ratification process, and adhere to the provisions in the Additional Protocol pending ratification. Third, Tehran would voluntarily suspend all uranium enrichment and reprocessing activities during the ongoing negotiations (while it would continue to assemble and test centrifuges) (ElBaradei, 2011, p. 121).

At the end of 2003, the EU and its member states again resisted the Bush administration’s pushing for a referral to the UN Security Council during the IAEA November meeting, which was then followed by the Iranian government’s decision to sign the IAEA Additional Protocol in December. Notably, not only did the IAEA resolution on November 26, 2003, for the first time welcome the E3 Tehran Agreement but an External Affairs Council meeting in December endorsed the E3 effort, requesting the EU High Representative to visit Tehran in January 2004 to discuss the prospect for the EU’s comprehensive dialogue with Iran. While some member states uttered reservations as to the format—with Italy and Spain complaining about their exclusion—the EU High Representative joined the E3 in early 2004, thereby representing the whole of the EU and reporting to all its major institutions, the EU Council, the Political and Security Committee, and the Parliament (Santini, 2010).

Over the course of 2004 more outstanding questions about past nuclear activities triggered harsher IAEA resolutions, albeit short of a UN Security Council referral, leading to the demise of the Tehran statement and the negotiation of the so-called Paris Agreement (PA) (November 15, 2004). The PA drew important lessons from the failure of the Tehran accord: First, it was a two-sided “agreement,” including the Iranian side, not a one-sided declaration. Second, it spelled out the terms and scope of the suspension of uranium enrichment and plutonium reprocessing in much greater detail, including procurement, conversion, assembly, production, and testing activities. Third, the agreement called for “objective guarantees” that Iran would not use its nuclear program for military purposes. Fourth, the PA defined that suspension would be essential, “while negotiations on a longer-term agreement are under way.” Fifth, the E3/EU offered more detailed benefits in exchange for Iranian cooperation, including political and economic inducements such as the resumption of talks on a trade and cooperation agreement. Last, the agreement provided for a steering committee, which was to convene three working groups on political and security issues (chaired by the United Kingdom), on technology and cooperation (chaired by Germany), and on nuclear issues (chaired by France; IAEA, 2004).

Given that the PA was negotiated by the EU High Representative and later endorsed by the GAERC, it is noteworthy that the PA delegated the chair-function of the working groups to the E3 countries, thereby signaling assent by all EU member states to this new division of labor. Also, the Bush administration moved closer to the EU3 position, realizing that without the EU it would be almost impossible to refer the Iran dossier to the UN Security Council, not to speak of common action in the Council itself (Bolton, 2007).

The first phase drew to a close when the EU tabled a proposal on August 5, 2005, that called for a permanent and legally binding suspension of all fuel cycle and enrichment activities in exchange for expanded political, security, economic, and technological relations after the conservative candidate, Mohammed Achmadinejad, had won the presidential elections in July 2005. Rejecting the EU proposal outright, Iran initiated uranium conversion activities in Esfahan, which, in turn, was considered by the EU as a clear breach of the PA, requiring further action in the IAEA. Thus, facing objections from Italy, Spain, and Portugal to refer the Iran dossier to the UN, all European IAEA board members endorsed the Board of Governor’s resolution on September 24, 2005, finding that Iran was in “non-compliance” with its IAEA Safeguards Agreement while not (directly) referring the matter to the UN (ElBaradei, 2011, p. 145). At this point, Russia offered a compromise so that Iran would carry out its enrichment activities on Russian soil under strict control, but Iran also rejected this compromise and restarted its enrichment in early 2006.

In sum, EU3’s role playing as an interlocutor emerged after the U.S. Bush administration had indicated that it may use a coercive strategy similar to the one in Iraq. This U.S. position triggered the E3 diplomatic initiative and the Iranian willingness to talk to the EU, aiming to prevent an immediate referral of the Iranian dossier from the IAEA to the UN Security Council (Kazemzadeh, 2017).

In turn, the EU3’s role grew and became more coherent over time. In this early phase E3 foreign ministers took the center stage in negotiating while the EU High Representative’s role remained secondary (Alcaro, 2018). Within the EU, both the composition and the strategy of the E3 initiative was contested as some member states argued for their inclusion (Italy, Spain) and some held that the EU-Iran negotiations on a TCA should not be linked to the nuclear issue (Italy, Austria, Spain). Analytically speaking, the United States’ conflictual role-taking in 2003 facilitated the EU3’s role-taking (and did not cause it), whereas E3 interaction with Iran and subsequent recognition of the EU3 mediation effort by Russia, China, and the IAEA Board of Governors strengthened the EU3’s role. Technically speaking, the E3 set the agenda by tying the deferment of the referral to the UN with the temporary suspension of fuel cycle activities. But when the Tehran Declaration collapsed, the EU High Representative became the optimal partner for the E3 because he could represent all member states and potentially bring additional EU assets to the negotiating table, to enhance the EU3’s standing as an interlocutor between Iran, Russia, and China on the one hand and the United States on the other.

The Second Phase, 2006–2012

As the interaction between Iran and the international community grew more conflictual, the scope and dynamics of the EU3’s mediator role changed substantially. In early 2006, the new Achmadinejad administration had restarted uranium enrichment. Consequently, the EU3 not only pleaded successfully in the IAEA to transfer the Iranian dossier to the Security Council but then also drafted a UN Security Council resolution that would legally oblige Iran to suspend enrichment activities, thus moving somewhat closer to the U.S. position. Russia and China rejected this draft, raising concerns about invoking Chapter VII and opening the way for sanctions or (potentially) even military measures. In response, the EU, under the leadership of High Representative Solana, prepared a package of incentives and obligations for Iran, thus enabling China and Russia to support the EU initiative.

The EU3+3 offer (June 1, 2006)–which now had the support of all permanent members of the Security Council, included two important novelties: still demanding the suspension of fuel-cycle activities during negotiations, the proposal “offered” a suspension review when Iran had met its obligations with the IAEA. Also, the plan foresaw an Iranian part-ownership of a plant in Russia to enrich Iranian-produced uranium (Council of the European Union, 2006). By mid-2007, the EU3’s facilitation of convergence among UN Security Council members started to bear fruit. But IAEA Director El Baradei sensed that Iran was making technical headway with the agency, while Western negotiators were set on a sanction-based approach. On Iran’s initiative, El Baradei therefore suggested the IAEA was ready to negotiate a “work plan” to settle some of the outstanding issues in Iran’s dossier (Kerr, 2017, p. 5). Further ambivalence ensued when a U.S. National Intelligence Estimate judged that Iran “had halted its nuclear weapons program in 2003 while keeping its options open to resume it” (as cited in Meier, 2013, p. 11), which became public in November 2007. On both counts, the EU3, and the United Kingdom and France in particular, insisted that even if the work plan worked, the dossier could not be closed and the dual approach of further talks and more sanctions had to be maintained.

Reflecting the consensus between hardliners and pragmatists in Tehran, Iranian lead negotiator Ali Larijani finally rejected the EU proposal, claiming that a permanent suspension of enrichment, albeit as a prerequisite for talks, was not negotiable. In response, the EU Council, representing the biggest single trading partner of Iran at the time, decided to support UN-based sanctions against Iran in late 2006. With Iran in constant defiance—raising enrichment levels to industrial scale in 2007—the EU High Representative still kept a dialogue with his counterpart, Ali Larijani, but France and the United Kingdom started to press for more restrictive unilateral EU sanctions that would go (far) beyond the UN Security Council–mandated ones. With several members objecting, among them Spain, Italy, Greece, and Germany, the EU Council reached a compromise for stronger UN-mandated sanctions and only a few additional EU measures. As a consequence, UN Security Council Resolution 1803 of March 3, 2008, not only extended trade, travel, banking, and monitoring restrictions but also, for the first time, banned trade in dual-use items. Most notably, this resolution recognized the EU3’s leading role in diplomacy and formally and explicitly mandated the EU High Representative to continue the dialogue to find a negotiated solution (United Nations Security Council, 2008).

While the newly elected U.S. president, Barack Obama, was ready to engage with Iran, Iranian footdragging and additional information on previously unknown nuclear sites in Fordow near Qom clearly shaped the EU3’s approach. First, Iran signaled its willingness for a fuel-swap agreement—low-enriched uranium from Iran would be further enriched in and returned from a third country in selected batches—and the EU3 (despite some misgivings whether this would later legitimize an Iranian enrichment program) consented (Meier, 2013). But then, Iran raised several conditions that led to the rejection by the EU3+3 and the adoption of further UN-mandated sanctions (Bowen, Moran, & Esfandiary, 2016).

Second, Iran approached Turkey and Brazil for a similar swap deal, and initially Western governments, most notably the Obama administration, gave their cautious support. The technical details of the proposed swap, monitored by the IAEA, raised few concerns, but the resulting Tehran Declaration by Iran, Turkey, and Brazil explicitly confirmed Iran’s inalienable right to nuclear energy. It included the full nuclear fuel cycle and enrichment activities (Joint Declaration), an anathema to various European and especially the U.S. government that subsequently called for and succeeded in implementing further United States–based sanctions against Iran, UN Security Council Resolution 1929 (Cronberg, 2017b).

Against this backdrop, the EU considerably expanded its own role over the course of 2010, adding unilateral EU sanctions to its strategy that consisted of bilateral diplomatic talks and UN-mandated sanctions. EU High Representative, Lady Catherine Ashton, called upon the new Iranian lead negotiator, Saeed Jalili, to continue to find a negotiated solution while the EU Council imposed a first batch of unilateral sanctions, restricting trade and financial, transportation, and energy sectors, including a full cessation of new investment in Iran’s energy sector (Council of the European Union, 2012). When the IAEA reported in November 2011 that Iran had, in defiance of the Security Council resolution, continued its uranium enrichment but also had taken some crucial steps needed to build nuclear weapons (i.e., a high explosive and hemispherical initiation system, with the help of foreign nuclear scientists), the EU imposed a second batch of unilateral sanctions (ElBaradei, 2011, paras. 43–45). This time the sanctions banned the import of Iranian oil and petroleum products as well as prohibited new oil deals. The latter restrictions are most noteworthy since several EU member states, which suffered from an economic downturn during the Eurocrisis (Greece, Spain, Italy), reaffirmed their commitment to the common EU sanctions despite their individual dependence on Iranian oil imports (Ali, 2018, p. 127). At a subsequent meeting in Baghdad, the EU3, now led by High Representative Catherine Ashton, presented the “stop, shut, and ship” plan. It included obligations to end the production of 20% enriched uranium, close the Fordow Fuel Enrichment Plant, and ship the remaining 20% stockpile out of the country for the production of fuel for the Tehran Research Reactor. Yet, substantial differences remained, and no further political negotiations were scheduled (Fabius, 2016, p. 8).

It is difficult to discern the effects of the EU sanctions on the Iranian negotiators (Anthony, Bromley, & Wezeman, 2016), but they immediately responded by calling for additional dialogue, albeit without directly addressing the EU’s demands (Ashton, 2012). While EU and U.S. unilateral sanctions on top of UN-mandated restrictions clearly slowed down Iranian economic activity and (possibly infused defiant behavior by a people accustomed to sanction), Iran managed to replace European ex- and imports with new trading partners in China, India, South Korea, Turkey, and elsewhere (Portela, 2015).

In sum, the EU3’s role expanded substantially and further stabilized through a complementary role-taking by the IAEA Board of Governors, EU member states, as well as other P5 member states joining the EU3 in early 2006 to become the EU3+3. To negotiate on behalf of Russia and China on the one hand and the United States on the other signaled that both sides deemed that they were better off with the EU3 mediating between them and the other P5 members as well as that they expected the EU to represent their position sincerely. This composite mandate on behalf of the international community—EU3-sponsored UN Security Council resolutions regularly raised few rejections and abstentions—is clearly reflected in Iran’s increasingly bifurcated negotiation strategy under President Achmadinejad, combining open defiance and provocation with accommodation. Iran’s attempt to circumvent the EU3-format, by approaching Turkey and Brazil in 2010, however, did not muster enough international support—not even from Russia and China—to rival the EU3’s role as the lead negotiator. In this phase, Javier Solana clearly became the lead interlocutor while the E3 foreign ministers took over a more seconding position, especially after their nations started punitive measures in the UN Security Council. When Lady Catherine Ashton took over the position in the aftermath of the Lisbon Treaty ratification in 2009, the EU High Representative’s role became more circumscribed, functioning more as a chairperson rather than as a lead interlocutor (Alcaro, 2018, p. 160).

The Third Phase, 2013–2019

The dynamics of Iran–EU relations, and the EU3’s role as a key negotiator, improved markedly in June 2013 after Hassan Rouhani, an experienced nuclear negotiator and moderate candidate won the Iranian Presidential election. Rouhani had run for Presidency on a pragmatist platform, foregrounding “moderation and justice not extremism” and constructive engagement with the international community (Gibson, 2015, p. 9). Against this background, the EU3, with EU HR Ashton in the lead, reengaged with Iran. The resulting JPA (November 2013) foresaw that Iran would freeze some of its most sensitive nuclear activities in exchange for partial sanctions relief in order to gain time for negotiating a larger settlement. Specifically, Iran’s uranium hexafluoride stockpile at the time was sufficient, upon further enrichment, to produce weapons-grade material for as many as eight nuclear weapons. In addition, the stockpile of 20% enriched uranium-235, after further enrichment, would have been sufficient for a nuclear weapon in a much shorter timeframe. Under the JPA, Iran had to convert much of that material to fuel for the Tehran Research Reactor or dilute the stockpile below 5% of uranium-235, thereby drastically reducing its breakout capacity (Katzmann & Kerr, 2017, p. 3).

The JPA only partially rested on the EU High Representative’s negotiations with Iran because upon request of President Obama, Iranian and U.S. officials had met secretly in Oman since March 2013. During these talks, U.S. officials presented a new proposal, reflecting major components of an earlier Iranian proposal, the Zarif Plan. For the first time, the package included an American acceptance of a limited and strongly monitored Iranian uranium enrichment capacity. While the P5+1 eventually accepted a revised version of the original proposal for the conclusion of the JPA, this “backchannel episode” set a competitive tone between the French and the United States’ negotiators, thereby complicating common EU3 leadership (Fabius, 2016).

The “U.S.-Iranian backchannel episode” also changed the structure of negotiations. On the one hand, talks between technical experts and principals (i.e., foreign ministers) intensified, often involving several meetings in different major cities in Europe and the Middle East. The U.S. negotiating team, led by Secretary of State John Kerry and Undersecretary of State Wendy Sherman and supported by Secretary of Energy Ernie Moniz, an experienced nuclear scientist, focused on Iran’s enrichment capacity, whereas the French team covered “possible military dimension” issues. Meanwhile, Russian and Chinese negotiators assessed options for an international consortium to swap parts of the low enriched uranium/highly enriched uranium stockpile in exchange for nuclear fuel and the conversion of the plutonium-based reactor in Arak.

On the other hand, while national officials pushed the negotiations forward, an intricate division of labor emerged among the P5+1 and the EU negotiation teams, including the EU top negotiator, Helga Schmid (de la Baume, 2015). Thus over the final three months, the EU3 negotiating team under the leadership of Federica Mogherini and Helga Schmid directed the drafting and final revisions of the JCPOA. This included in-depth consultations with the IAEA and meditation between the EU High Representative, France, and the United States on the sequence of the lifting of sanctions (Ali, 2018; Fabius, 2016).

After extending the “suspension period” for uranium enrichment activities and further sanctions several times, the parties finally announced the JCPOA in June 2015. The JCPOA limits Iran’s enrichment and heavy water reactor programs for up to 15 years. It also establishes an elaborate monitoring system designed to detect Iranian efforts to produce nuclear weapons in declared or covert facilities. Moreover, the JCPOA also indefinitely prohibits Iranian “activities which could contribute to the design and development of a nuclear explosive device,” including research and diagnostic activities (Samore, 2015).

Most experts agree that, if fully implemented, the JCPOA’s limits on fissile-material production and its verification and monitoring provisions make it almost impossible for Iran to develop nuclear weapons at its declared nuclear facilities for 10 to 15 years (Allison, 2015; Crowley, 2015; Mecklin, 2015). While the restriction on plutonium production are strong, the limits on the existing uranium enrichment facilities are less prohibitive, allowing for a shorter “breakout time,” if Iran chooses to depart from its commitments during or after the 15-year suspension period (Samore, 2015). It follows that the JCPOA almost certainly will prevent Iran from acquiring or even producing nuclear weapons for the next 15 years, but it does not eliminate the possibility of that risk after the suspension period ends.

In contrast, critics of the JCPOA, in particular Republican members of U.S. Congress as well as the candidate and later U.S. President Donald Trump, have argued that the verification of the suspension is too weak to detect clandestine Iranian activities. Further, they assume that the deal leaves Iran with critical enrichment infrastructure that could be easily restarted and expanded to produce nuclear weapons on short notice (Dubowitz, 2015). Moreover, these critics assail the fact that the JCPOA does not address Iran’s ballistic missile program or its aggressive regional activities, such as in Syria, Yemen, or Lebanon (Goldenberg et al., 2015).

Since taking office in January 2017, the Trump administration followed first a two-pronged strategy: on the one hand, the president (and some senior officials) would harshly criticize the deal as weak and as not in the best interest of the United States and its allies. Hence, the administration supportive of a more aggressive sanction regime, thus necessitating additional sanctions against Iranian expansive behavior in the region. On the other hand, President Trump would certify Iran’s compliance with the JCPOA—both the IAEA’s and the U.S. intelligence community’s findings supported this conclusion—following the advice of his Secretaries of State (Tillerson) and Defense (Mattis).

By mid-2017, the U.S. president, however, asked White House aides to prepare a rationale for declaring Iran in noncompliance. Moreover, the administration was working on a new Iran strategy, foregrounding the containment and rollback of the Iranian influence in the Middle East (Simon, 2018). In January 2018, then, the U.S. administration started pressing Europe hard, arguing that it would renew waivers for nuclear-related sanctions only to give the EU3 and Congress time to fix the deal’s disastrous flaws. While the EU3 started talks with the Iranians over contentious issues regarding its ballistic missile program and regional behavior, President Trump declared in May 2018 that the United States was withdrawing from the JCPOA and imposing the highest level of economic sanctions on Iran (The White House, 2018). Laying out the contours of the new Iran strategy, Secretary of State Pompeo declared that the United States would apply maximum pressure for Iran to change its behavior. But he also stressed that the Trump administration would be willing to negotiate a comprehensive agreement, if Iran meets 12 demands, 4 of which were concerned with nuclear nonproliferation (Pompeo, 2018).1

In response, EU High Representative Federica Mogherini and the EU3 consulted over the second half of 2018 with Iranian as well as Russian, Chinese, and other officials about the ways and means to preserve the JCPOA while addressing Iranian malfeasance in the region and beyond. First, to forestall the collapse of the accord, the EU has taken a series of measures, including an enhanced blocking statute to prevent extraterritorial U.S. sanctions from hindering European exports to Iran (August 2018) and a special purpose vehicle established by France, Germany, and the United Kingdom (called INSTEX, January 2019), designed to focus on facilitating trade in sectors most essential to the Iranian population—such as pharmaceutical, medical devices, and agri-food goods (European Commission, 2018; Geranimeh & Batmanghelid, 2019). Second, the EU imposed sanctions in January 2019 against Iranian intelligence services and two individuals for planning the assassination of regime opponents residing in the Netherlands, France, and Denmark. Moreover, the Council has called upon Iran to end its unacceptable behavior in the region, including the test of ballistic missile technology in 2019 (Brzozowski, 2019).

In sum, through the JCPOA, the EU3 initiative managed to address the two most pressing security policy challenges in 2003: the internal division over the Iraq intervention and the potential subsequent erosion of nonproliferation regime in the aftermath of the Iraq conflict and the North Korean withdrawal from the NPT. Focusing on the internal divisions in the EU, the EU3 initiative addressed cleavages over nonproliferation norms (e.g., whether Iran had foregone its right to all fuel-cycle activities forever—Germany opposed vs. France and the United Kingdom leaning toward it) and coercive diplomacy, most notably economic sanctions (southern EU members with extensive business ties more opposed vs. northern members by trend more in favor).

Focusing on the potential erosion of the nonproliferation regime, the EU3 mediation also effectuated the IAEA-based compliance procedure, starting with enhanced IAEA safeguard procedures, the regular involvement of the IAEA Board of Governors, conditions set for the transfer to the UN Security Council, and the use of Chapter VII procedures to legitimize coercive economic and military sanctions to change the policy preferences of the targeted state (Santoro, 2016). In doing so, the EU3 also contributed to a new consensus on what a “significant quantity” (SQ) of weapons-grade material is. In the JCPOA, the EU3 together with its partners defined the SQ metric in terms of the time within which a nuclear-capable state can produce enough weapons-grade material for at least one nuclear device. Notably, this understanding falls in the middle of the spectrum of interpretations of the SQ metric of the parties concerned: On the restrictive end of the spectrum, the Bush administration and Israel argued that potential proliferators should not have access to full-fuel cycle activities at all (i.e., uranium enrichment and plutonium reprocessing), because that would eventually allow them to produce significant quantities of weapons-grade material.2 On the other end, according to the Russian and Chinese interpretations, Iran should be prevented from holding a significant quantity of weapons-grade material while it may enjoy full access to fuel-cycle activities under IAEA safeguards, even before all past safeguard violations had been addressed. It follows then that the JCPOA sets out specific limitations for the centrifuge design, number of centrifuges and centrifuge facilities, level of enrichment, centrifuge production and research and development, as well as the stockpile and quality of enriched uranium (Katzmann & Kerr, 2017) to reach a consensus on what specific remedial action a NPT member that is not in good standing has to take to rehabilitate itself. In effect, the JCPOA thereby stabilizes the nonproliferation regime because it specifies the rules under which members not in good standing can recuperate their prior status. Moreover, the JCPOA also—through UN Security Council Resolution 2231—considerably broadens the IAEA’s country-specific authority to monitor Iran’s nuclear program, even if these advanced safeguards are unlikely to be applied ever to other alleged proliferators in the future (Hibbs, 2015; Kerr, 2017). Finally, by effectuating the standard procedure of the nonproliferation regime, the EU3 and the Obama administration prevented Israel from conducting a preemptive strike on Iranian facilities, thereby holding fast to a rule-based nonproliferation order.


The EU’s relationship with Iran has become increasingly important for the emergence of the EU as an international security actor. As a product of member states and institutional choices as well as interactions with Iran, the Union has developed substantial capacity and reputation to act in the field of nonproliferation policy. In doing so, the relationship with Iran illustrates some broader trends in the EU’s foreign and security policymaking process and the EU’s role in the world.

First, the EU’s relationship with the revolutionary regime has helped to forge a distinct EU approach of engaging with outsiders, often called rogue nations, in the international society. In the 1980s and 1990s (and through the 2010s), Iran’s state support of terrorist groups in the Middle East as well as illicit activities to kill or threaten regime critics on European soil have been met by the EU’s member states with the attempt to entangle the regime and the Iranian people in a web of economic interdependencies to moderate the regime’s behavior and strengthen pragmatic and liberal forces within the theocratic republic. While this EU working consensus to engage in a critical or comprehensive dialogue with Iran has been repeatedly challenged by the United States, claiming hypocrisy or naivety or both, and by illicit Iranian behavior, triggering domestic opposition and critique, the EU and its member states have held fast to the strategy of including rather than segregating problematic actors.

Second, the EU’s Iran policy highlights the effects of the interaction with Iran in comparison to other factors, such the EU’s internal or institutional dynamics or U.S. policy preferences, when explaining the policy process between EU institutions and member states. Despite almost constant U.S. opposition to the EU’s engagement with Iran, discernible steps toward a common position, if not yet a common policy, such as the joint response toward the fatwa against Salman Rushdie or the regime’s leadership collusion in the killing of opponents in Berlin (Mykonos Affair), emanated from the adversarial interaction with Iran rather than from internal institutional changes, such as the introduction of the Common Foreign Security Policy (Maastricht) or the establishment of the position of the EU High Representative (Amsterdam). In this way, the interaction with Iran as an outsider in the nuclear nonproliferation regime shaped the EU as an important insider of the regime. Over the course of the EU3 initiative, prior policy differences between member states were ironed out and a common strategy was developed and implemented.

Third, with the Trump administration abandoning the normative and institutional underpinnings of a liberal rules-based international order, the EU’s engagement with Iran under the JCPOA has become a case study for both how coherent a nonproliferation actor the EU has become and how long the EU’s effective multilateralism may persist when opposed by the United States. While the odds that the U.S. strategy of maximum pressure will achieve any substantial behavioral change in Iran are low, the Iranian regime’s policy choices are probably more determined by its interactions with Western and Arab forces in Syria, and Yemen, Lebanon than by the EU. As a consequence, the EU’s effort to stabilize and enhance the current nonproliferation regime may have given pause to the Iranian nuclear question but certainly has not given a definite answer to it.


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(1.) These demands were that Iran must provide more information on past nuclear weapon work, end all uranium enrichment and reprocessing, stop developing and exporting ballistic missiles, and give IAEA inspectors unlimited access to all sites throughout the country.

(2.) Over the course of the Iranian crisis, the Israeli government under Prime Minister Netanyahu discussed two intervention points: first, setting a limit of approximately 200 kg of 20% enriched uranium in Iran’s possession, which would potentially enable Tehran to quickly (within six months) produce one nuclear warhead; second, shifting substantial uranium enrichment production capacity to the hardened facility in Qom, thereby creating a “zne of immunity”(cf. Merom, 2017; Zanotti, Katzman, Gertler, & Hildreth, 2012).