Overview
On September 29, 2025, the Council of the European Union (EU) reimposed a comprehensive set of restrictive measures against Iran, which had been lifted in 2015 with the entry into force of the Joint Comprehensive Plan of Action (JCPOA). This move follows the recent “snapback” of the UN’s nuclear‑related sanctions on Iran, after the UN Security Council’s (UNSC) failure to adopt a resolution extending sanctions relief.
The EU’s restrictive measures against Iran are outlined in six legal instruments. Four of these—Council Decision (CFSP) 2025/1978, Council Implementing Decision (CFSP) 2025/1971, Council Implementing Regulation (EU) 2025/1980, and Council Implementing Regulation (EU) 2025/1982—entered into force on September 29. The remaining two instruments in the package, Council Regulation (EU) 2025/1975 and Council Decision (CFSP) 2025/1972, entered into force on September 30.
Collectively, the six instruments implement measures previously adopted by the UNSC and transposed into EU law, along with additional autonomous EU restrictive measures. These measures significantly restrict trade with Iran and target key sectors of Iran’s economy, including finance and transportation.
Trade restrictions
The reimposed EU sanctions ban trade in a wide range of goods and technology by prohibiting export to, and import from, Iran of the following items:
- Dual-use goods and technology;
- Other goods and technology which can contribute to Iran’s proliferation-sensitive nuclear activities, the development of nuclear weapon delivery systems, or the sensitive activities identified by the International Atomic Energy Agency (IAEA); and
- Gold, precious metals and diamonds.
The EU sanctions further prohibit sale, supply, transfer or export of the following items to any Iranian person or entity, or for use in Iran:
- Key equipment and technology for the key sectors of Iran’s oil and gas industry (exploration or production of crude oil and natural gas, refining, and liquefaction of natural gas);
- Key equipment and technology for Iran’s petrochemical industry;
- Key naval equipment or technology for shipbuilding, maintenance or refit;
- ERP software designed specifically for use in the nuclear, military, oil, gas, navy, aviation, financial, and construction industries; and
- Graphite and raw or semi-finished metals, such as aluminium and steel.
The EU sanctions also restrict import into the EU, purchase, and transport of crude oil or petroleum products, petrochemical products, and natural gas which originate in or are exported from Iran. The EU also prohibits swapping natural gas which originates in Iran or has been exported from Iran.
Finally, as is the case with most EU sanctions regimes, the trade sanctions against Iran prohibit providing technical assistance, broking services, and/or financing or financial assistance, including insurance and reinsurance, related to the above-mentioned restricted goods and technology, as well as goods and technology listed in the Common Military List (CML).
Targeted financial sanctions
The EU has re-designated over 200 persons and entities that are subject to an asset freeze and a prohibition to make funds or economic resources available to them. EU operators are also prohibited from supplying specialised financial messaging services, which are used to exchange financial data to the designated persons or entities.
Restrictions on access to finance and financial services
The EU has reinstated a number of sanctions which are intended to constrain Iran’s access to international financial networks and prevent the funding of prohibited activities, including:
- A prohibition on granting any financial loan or credit to, acquire or extend a participation in, or create a joint venture with, any Iranian person or entity which is engaged in:
- the manufacture of goods or technology listed in the CML, dual-use goods, or goods or technology which can contribute to Iran’s proliferation-sensitive nuclear activities, the development of nuclear weapon delivery systems, or the sensitive activities identified by IAEA;
- the exploration or production of crude oil and natural gas, the refining of fuels, or the liquefaction of natural gas; or
- the petrochemical industry;
- A prohibition on establishing cooperation with Iranian persons or entities engaged in the transmission of natural gas;
- A prohibition on the transfer of funds between EU banks or financial institutions and Iran-domiciled banks or financial institutions, including their branches and subsidiaries, or non-Iranian banks or financial institutions, which are controlled by Iranian persons or entities;
- A prohibition for EU banks or financial institutions on opening a new bank account and establishing correspondent banking relationships or a new joint venture with Iran-domiciled banks or financial institutions, including their branches and subsidiaries, or non-Iranian banks or financial institutions, which are controlled by Iranian persons or entities;
- A prohibition on the sale or purchase of public or public-guaranteed bonds, issued after 30 September 2025, to or from: Iran or its government, public entities, Iran-domiciled banks or financial institutions, including their branches and subsidiaries, as well as persons or entities acting on behalf or at the direction of, or that are owned or controlled by, the relevant Iranian entities;
- A prohibition on providing or brokering the provision of insurance or reinsurance to Iran or its government, public entities, any other Iranian person or entity, as well as persons or entities acting on their behalf or at their direction; and
- Restrictions on the transfer of funds to, and from, Iranian individuals and entities.
Restrictive measures on the transport sector
The EU has also reimposed the following restrictive measures targeting Iran’s transport sector:
- A prohibition on providing bunkering or other ship supply services, or any other servicing of vessels, to Iranian vessels suspected of carrying goods listed in the CML or other goods whose supply, sale, transfer or export is prohibited under the EU sanctions;
- A prohibition on providing engineering and maintenance services to Iranian cargo aircraft suspected of carrying goods listed in the CML or other goods whose supply, sale, transfer or export is prohibited under the EU sanctions;
- A prohibition on providing a wide range of services in relation to oil tankers and cargo vessels flying the Iranian flag or owned, chartered, or operated, directly or indirectly, by an Iranian person or entity;
- A prohibition on making available vessels designed for the transport or storage of oil and petrochemical products to any Iranian person or entity.
The reimposed EU sanctions further require that all cargo to and from Iran within the territory of EU Member States must be inspected when there are reasonable grounds to believe it contains prohibited goods or technology. Inspections may also be requested on the high seas, with the consent of the flag State.
Impact on EU Operators
According to Eurostat, total trade in goods between the EU and Iran in 2024 amounted to €4.5 billion. The EU’s exports amounted to €3.7 billion, and imports amounted to €0.8 billion. Machinery, appliances, chemicals, and optical or photographic instruments constituted almost 90% of the EU’s exports to Iran in 2024. In addition, two-way trade in services between the EU and Iran totalled €1.68 billion in 2023.
The reimposed EU sanctions against Iran introduce legal and operational constraints that may impact ongoing and planned commercial activities of EU operators. EU companies with Iran-related operations must reassess their business relationships, contractual obligations, and supply chain dependencies to ensure compliance with the EU sanctions framework.
EU operators have a limited window of time to review their operations. The majority of the EU sanctions prohibitions include transitional provisions under which contracts concluded before September 30, 2025, along with any ancillary agreements necessary for their execution, may be performed until January 1, 2026 (subject to certain conditions in relation to specific EU sanctions prohibitions).
For more information on these developments and their implications, contact Guy Soussan or another member of Steptoe’s Economic Sanctions team in Brussels.
