After France and Germany spoke out in favour of reintroducing UN sanctions in accordance with Resolution 2231 (2015) of the UN Security Council, and the UN Security Council did not adopt a new resolution to continue lifting the Iran sanctions, Regulation (EU) 2025/ 1975 amending Regulation (EU) 267/2012 reintroduced the restrictive measures against Iran (known as the ‘snap-back’). The sanctions entered into force on 30 September 2025 and essentially include the following restrictions:

 

  • Prohibition on the export and import of dual-use goods (Annex I) in accordance with Art. 2. Exceptions to this are goods listed in Annex I Part A of this Regulation and exports for the purposes of Art. 6. A grandfather clause for the fulfilment of contracts concluded before 30 September 2025 until 1 January 2026 only applies to goods listed in Annex I, Part C. Exemptions may be granted for food, agricultural, medical or humanitarian purposes in accordance with Article 7.
  • Prohibition on the export and import of other nuclear-related goods listed in Annex II in accordance with Article 2. These include goods that could contribute to Iran’s enrichment, reprocessing or heavy water activities or to the development of nuclear weapon delivery systems. Exports for the purposes of Article 6 are exempt from this. No grandfather clause is provided for. Exemptions may be granted for food, agricultural, medical or humanitarian purposes in accordance with Article 7.
  • Export ban on key equipment in the energy sector (Annexes VI and VIa) in accordance with Article 8. This refers to key equipment for the key sectors of the oil and gas industry and petrochemicals. A grandfather clause exists for the execution of transactions until 1 January 2026 for contracts concluded before 30 September (Article 10).
  • Export ban on key marine equipment (Annex VIb) in accordance with Art. 10a. This includes essential marine equipment and technology for the construction, maintenance or conversion of ships, including the construction of oil tankers. An exception to the ban applies in cases of force majeure (Art. 10c (1)). In addition, there is a grandfather clause for the fulfilment of contracts concluded before 30 September 2025 until 1 January 2026 (Art. 10c (2)).
  • Export ban on enterprise software (Annex VIIa) pursuant to Art. 10d Annex VIIa covers software relevant to the integration of industrial processes, Iran’s nuclear or military programme, or its ballistic missile programme. The ban does not apply to the fulfilment of contracts concluded before 30 September 2025 until 1 January 2026 (Article 10f).
  • Export and import bans on gold, precious metals and diamonds (Annex VII) pursuant to Article 15.
  • Export ban on graphite, raw metals or semi-finished metal products such as aluminium and steel (Annex VIIb) in accordance with Art. 15a. Exempted from this is the fulfilment of contracts concluded before 30 September 2025 until 1 January 2026 (Art. 15c).
  • Export ban on Iranian currency banknotes in accordance with Art. 16.
  • Import ban on petroleum products (Annex IV) in accordance with Art. 11, with a grandfather clause for the fulfilment of contracts concluded before 30 September 2025 until 1 January 2026 (Art. 12).
  • Import ban on petrochemical products (Annex V) in accordance with Art. 13, with a grandfather clause for the fulfilment of contracts concluded before 30 September 2025 until 1 January 2026 (Art. 14).
  • Import ban on natural gas (Annex IVa) in accordance with Art. 14a. There is no grandfather clause for this.
  • Authorisation requirement for the export of goods listed in Annex IIa in accordance with Art. 3. Annex IIa contains additional goods that may contribute to activities related to enrichment, reprocessing or heavy water, or to the development of delivery systems for nuclear weapons.
  • Freezing order and prohibition on making funds available for persons listed in Annexes VIII and IX in accordance with Article 23.
  • Financial sanctions for certain companies in the oil and gas industry, petrochemical industry (Article 17) and Iranian banks (Article 30).

 

Further information

Further information can be found on EUR-Lex and on the Zoll.de (Germal language)