Does all this talk of centrifuges and snap-back sanctions have your head spinning? You’re not alone. The details of the Iran nuclear deal are a bit complex, and figuring out just what is supposed to happen when can be tricky, even for those who do this for a living.
Luckily, Staley Smith and Quinta Jurecic, two bright minds over at the Brookings-affiliated blog Lawfare, have put together a detailed summary of the timing of obligations and activities triggered at each step of the Iran deal, including exactly when various sanctions will be relaxed or terminated and when the various restrictions on the Iranian nuclear program are slated to end.
We’ve reprinted it here for you, but be sure to check out all the commentary on Iran and the full array of issues related to national security law and policy over at Lawfare, whose editor-in-chief, Benjamin Wittes, and managing editor, Wells Bennett, are scholars in Brookings Governance Studies program.
Finalization Day (July 14, 2015)
- The day the agreement was reached and endorsed by Iran and the P5+1
- The deal will be “promptly” submitted to the United Nations Security Council (UNSC) for endorsement
The United Nations Security Council endorses the Joint Comprehensive Plan of Action (JCPOA) (July 20, 2015)
UNSC votes unanimously to:
- endorse the JCPOA
- “terminate” all prior UN sanctions, beginning on Implementation Day (and subject to re-imposition through snapback mechanism)
President Submits Agreement to Congress & 60-Day Congressional Review Period (July 20-September 17, 2015)
- After all relevant documents are submitted to Congress (July 19, 2015), both houses of the U.S. Congress will have 60 days to vote on the deal, as required by the Iran Nuclear Agreement Review Act, sponsored by Senator Bob Corker (R-TN)
- During this time, President Obama is prohibited from lifting sanctions on Iran
Adoption Day (October 2015)
- 90 days after the UNSC endorses the JCPOA, OR an earlier date mutually agreed upon by participants in the JCPOA.
- The “JCPOA and the commitments in the JCPOA” come into effect
- Participants in the JCPOA will begin making “necessary arrangements and preparations” to implement their commitments under the JCPOA
Implementation Day (Early 2016)
The day on which the IAEA report verifies that Iran has done the following:
Arak Heavy Water Research Reactor
- that Iran has ceased pursuing construction at the existing Arak Heavy Water Reactor based on its original design
- that Iran has removed existing calandria from Arak, and that the calandria have been made inoperable
- that Iran is not producing or testing natural uranium pellets, fuel pins or fuel assemblies designed for the original Arak reactor
- IAEA will monitor all existing uranium pellets, until the modernized Arak reactor becomes operational at which point the natural uranium pellets and IR-40 fuel assemblies will be converted to UNH
- that Iran has made necessary technical modifications to the existing natural uranium fuel production process line for the modernized Arak reactor
Heavy Water Production Plant
- that all excess heavy water beyond Iran’s needs for the modernized Arak research reactor are being made available for export (for 15 years)
- that Iran has informed the IAEA about the inventory and production of the Heavy Water Production Plant and allows for monitoring
Enrichment Capacity
- that Iran is keeping its enrichment capacity at under 5060 IR-1 centrifuges, in no more than 30 cascades in their current configuration at Natanz Fuel Enrichment Plant (for 10 years)
- that Iran is keeping its level of uranium enrichment below 3.67 percent (for 15 years)
- that Iran has removed all additional centrifuges and infrastructure (not associated with the 5060 IR-1 centrifuges in FEP) and placed them in Natanz under continuous monitoring
Centrifuges Research and Development
- that ongoing enrichment R&D does not accumulate enriched uranium
- that enrichment R&D with uranium includes only IR-4, IR-5, IR-6 and IR-8 centrifuges. Mechanical testing is carried out only on the IR-2m, IR-4, IR-5, IR-6, IR-6s, IR-7 and IR-8, and only one or two of each type. Iran is building or testing only those gas centrifuges specified in this JCPOA (10 years)
- that all testing of centrifuges with uranium is taking place only at the PFEP, and all mechanical testing of centrifuges is only at its Pilot Fuel Enrichment Plant (at Natanz) and The Tehran Research Center (15 years)
- that Iran has adapting PFEP to the its long-term R&D plan, by removing and modifying all excess infrastructure and equipment in specified ways of Annex IIG
Fordow Fuel Enrichment Plant
- that Iran is not conducting any uranium enrichment or related R&D and has no nuclear material at the Fordow Fuel Enrichment Plant (for 15 years)
- that Iran is maintaining no more than 1044 IR-1 centrifuge machines, that they are in one wing of the FFEP, and that have been structured in specific ways: two cascades modified for production of stable isotopes and four cascades remaining idle (for 15 years)
- that Iran has removed the remaining cascades and infrastructure
- (All of these will be placed in Natanz under IAEA continuous monitoring, but the IAEA is not required to certify that at this stage)
Other Aspects of Enrichment
- that Iran is abiding by its voluntary commitments under its long-term R&D plan
- The IAEA will monitor and approve annually for the duration of the plan that the nature, scope and scale of Iran’s enrichment program.
- that a template for describing different centrifuge types and associated definitions, and a procedure for measuring centrifuge performance data has been agreed on.
- that all enriched uranium hexafluoride in excess of 300 kg of up to 3.67% enriched UF6 (or the equivalent in different chemical forms) will be down blended to natural uranium level or be sold and delivered on the international market
- that all uranium oxide enriched to between 5% and 20% has been fabricated into fuel plates for the Tehran Research Reactor or transferred outside of Iran or diluted to an enrichment level of 3.67% or less
- that Iran is not building or operating facilities for converting fuel plates or scrap back to UF6 (for 15 years)
Centrifuge Manufacturing
- that Iran is replacing broken or damaged active IR-1 centrifuges only from its stock of monitored stock of machines, and that the only centrifuges Iran is producing are to keep the store of IR-1s from dipping below 500
Additional Protocol and Modified Code 3.1
- that Iran has notified the IAEA of its provisional implementation of the Additional Protocol and full implementation Modified Code 3.1
Centrifuge Component Manufacturing Transparency
- that Iran has provided the IAEA with an initial inventory of all existing centrifuge rotor tubes and bellows is providing reports (and allowing verification) on changes in inventory
- that Iran has declared all locations and equipment that are used for the production of centrifuge rotor tubes or bellows and permitted continuous IAEA monitoring
Simultaneously, the EU terminates the provisions of the Council Regulation (EU) No 267/2012 and suspends the corresponding provisions of Council Decision 2010/413/CFSP. (Member states will change national legislation to follow suit.) EU sanctions lifted include:
Financial, banking and insurance measures:
- Prohibition and authorization regimes on financial transfers to and from Iran
- Sanctions on:
- banking activities
- insurance
- financial support for trade with Iran
- grants, financial assistance and concessional loans
- Government of Iran public-guaranteed bonds
- associated services for each of the categories above
Oil, gas and petrochemical sectors
- Sanctions on:
- the import of oil and gas from Iran
- the export of key equipment for the oil, gas and petrochemical sectors
- investment in the oil, gas and petrochemical sectors
- associated services for each of the above categories
Transport, metals, software sectors
- Sanctions related to:
- shipping and shipbuilding
- the transport sector
- metals
- software
- associated services for each of the categories above
Persons, entities and bodies
- Asset freeze and visa ban measure applicable to:
- listed Iranian banks and financial institutions, including Central Bank of Iran
- listed persons, entities and bodies related to:
- the oil, gas and petrochemical sectors
- shipping, shipbuilding and transport
- proliferation-sensitive nuclear-, arms- and ballistic missile-related activities
- other listed persons, entities and bodies not related to proliferation-sensitive nuclear-, arms- and ballistic missile-related activities
Simultaneously, the United States “ceases the application” of the following sanctions:
Financial and banking measures
- Sanctions on:
- transactions with individuals and entities set out in Attachment 3 to this Annex, including: the Central Bank of Iran (CBI) and other specified Iranian financial institutions; the National Iranian Oil Company and other specified individuals and entities identified as Government of Iran; Persons and entities involved in nuclear or ballistic missiles activities; Islamic Revolutionary Guard Corps (IRGC), Islamic Republic of Iran Shipping Lines (IRISL)
- Iranian Rial
- provision of U.S. banknotes to the Government of Iran
- the purchase, subscription to, or facilitation of the issuance of Iranian sovereign debt, including government bonds
- financial messaging services to the CBI and Iranian financial institutions
- Bilateral trade limitations on Iranian revenues held abroad, including limitations on their transfer
- Sanctions on associated services for each of the categories above
Insurance measures
- Sanctions on underwriting services and insurance
Energy and petrochemical sectors
- Efforts to reduce Iran’s crude oil sales, including limitations on the quantities of Iranian crude oil sold in those nations that are still permitted to purchase Iranian crude oil
- Sanctions on:
- investment and support for Iran’s oil, gas and petrochemical sectors
- the purchase, acquisition, sale, transportation or marketing of petroleum, petrochemical products and natural gas from Iran
- the export, sale or provision of refined petroleum products and petrochemical products to Iran
- transactions with Iran’s energy sector, including front companies
- associated services for each of the categories above
Shipping, port, metals and automotive sectors
- Sanctions on:
- transactions with Iran’s shipping and shipbuilding sectors and port operators
- Iran’s trade in gold and other precious metals
- the sale, supply or transfer of goods and services used in connection with Iran’s automotive sector
- associated services for each of the categories above
Designations and other sanctions listings
- Removal of hundreds individuals and entities set out in Attachments 3 and 4 of Annex II from the Specially Designated Nationals and Blocked Persons List (SDN List), the Foreign Sanctions Evaders List, and/or the Non-SDN Iran Sanctions Act List
The United States also commits to:
- allow for the sale of commercial passenger aircraft and related parts and services to Iran by licensing the:
- export or transfer to Iran of commercial passenger aircraft for exclusively civil aviation end-use
- export or transfer to Iran of spare parts and components for commercial passenger aircraft
- provision of associated services, including warranty, maintenance, and repair services and safety-related inspections, for all the foregoing, provided that licensed items and services are used exclusively for commercial passenger aviation
And, in accordance with an earlier UN Security Council resolution, the following UN sanctions are terminated, “subject to re-imposition in the event of significant non-performance by Iran of JCPOA commitments”:
- demands that Iran suspend all enrichment-related and reprocessing activities, including research and development, to be verified by the IAEA
- calls on all States to prevent the transfer of any items and technology that could contribute to Iran’s enrichment-related and reprocessing activities and ballistic missile programs
- demands that Iran cooperate with and provide access to the IAEA
- orders Iran to suspend all enrichment-related and reprocessing activities and heavy-water projects
- orders all states to prevent the transfer of materials, or technical or financial assistance, related to enrichment, reprocessing, heavy water, the development of a nuclear weapon, and activities about which IAEA has expressed concern. Also bans their import from Iran.
- freezes funds of designated individuals directly associated with Iran’s proliferation sensitive nuclear and missile activities
- prohibits technical cooperation on “proliferation sensitive nuclear” activity
- requires states to notify the UN of entry into territory of certain individuals involved in nuclear research
- prohibits the import of arms from Iran
- prohibitions grants and loans to the government of Iran
- requires states to notify the UN of the entry into their territory of certain individuals involved in nuclear research, and to prevent the entry of others
- imposes sanctions on materials related to nuclear weapons and ballistic missiles
- imposes financial sanctions on trade issues related to nuclear development
- reaffirms sanctions listed in the above resolutions
- prohibits foreign investment in uranium mining, uranium enrichment or reprocessing, and technology related to ballistic missiles
- imposes additional sanctions on conventional arms, ballistic missiles , individuals or entities belonging or controlled by the Revolutionary Guard, or involved in ballistic missiles or nuclear weapons industries
- extends sanctions listed in 1929 (2010) through June 2016
- re-imposes the ballistic missiles and conventional arms embargos. The ballistic missile sanctions will be lifted on Transition Day, while the conventional arms sanctions will be lifted five years after Adoption Day
- conclusion of consideration of the Iran nuclear issue by the UN Security Council 10 years after the Adoption Day
5 years after Adoption Day (October 2020)
- UN sanctions on conventional arms lifted
- May also occur earlier, if the IAEA reaches the “Broader Conclusion” that “all nuclear material in Iran remains in peaceful activities”
Transition Day, 8 years after Adoption Day (October 2023)
- UNSC sanctions on ballistic missiles are lifted
- May also occur earlier, if the IAEA reaches the “Broader Conclusion” that “all nuclear material in Iran remains in peaceful activities”
- Iran must seek ratification of the Additional Protocol on Nuclear Safeguards, which it signed in 2003 but has never formally “concluded.” (According to Iran, ratification by the Majlis is necessary for the Iranian government to conclude the Additional Protocol.)
The EU must lift the following sanctions:
- prohibiting the supply of financial messaging services to, and freezing the assets of, designated individuals “involved in nuclear or ballistic missiles activities,” and “owned, controlled, or acting on behalf of” the Revolutionary Guard and the Islamic Republic of Iran Shipping Lines.”
- (The JCPOA references Article 20(12) of Council Decision (EU) 2010/413/CFSP. Strangely, there is no Article 20(12); perhaps this is referencing Article 20(1-2), which would make the most sense contextually.)
- requiring inspection of cargo traveling to and from Iran; prohibiting the provision of maintenance services to cargo aircraft until suspect cargo is inspected and/or seized.
- prohibiting the sale or transfer or financing of nuclear related materials to Iran
- Materials listed in the Nuclear Suppliers Group (one, two) and Missile Technology Control Regime lists
- Materials determined by the Security Council, the UNSC-established Sanctions Committee, or the IAEA to contribute to nuclear enrichment or the development of nuclear weapons delivery systems
- Dual-use technology as listed in Annex I to EU Regulations
- prohibiting loans, credits or joint ventures with Iranian individuals or entities involved in the manufacture of materials listed in the Common Military List of the EU or technology that could contribute to nuclear enrichment or nuclear weapons delivery systems
- prohibiting investments in Iran that involve uranium mining, uranium enrichment, or the manufacture of materials listed in the Nuclear Suppliers Group (one, two) and Missile Technology Control Regime lists
- prohibiting buying and selling precious metals to and from the Iranian government.
- (Many of these seem to be misnumbered: for instance, there are no “Articles 4e and 4f” of Council Decision 2010/413/CFSP, and “Articles 15a, 15b and 15c” of Council Regulation (EU) No 267/2012 should be 15(1)a, b, and c)
- prohibiting the sale of software and “associated services” to Iran (these also appear to be misnumbered)
- prohibiting the sale or transfer of “arms and related materiel,” including military or paramilitary equipment, to Iran, and the import of arms from Iran
- prohibiting technical or financial assistance related to designated materials and loans or financial relationships with any Iranian individual involved in the manufacture of such goods
- freezing assets and banning visas for Iranian banks, financial institutions, individuals and entities related to “oil, gas, and petrochemical sectors,” shipping and transport, “proliferation-sensitive” activities, and nuclear weapons and ballistic missiles
The United States must seek legislative action to effect the complete termination of:
- those sanctions suspended since Implementation Day, including those targeting Iran’s financial, energy, shipping, automotive sectors and petrochemical measures
- sanctions on the acquisition of nuclear-related commodities and services (under the Iran, North Korea, and Syria Nonproliferation Act)
- sanctions on joint ventures relating to the mining, production, or transportation of uranium
- the exclusion of Iranian citizens from higher education coursework related to careers in nuclear science, nuclear engineering or the energy sector
- sanctions on raw and semi-finished metals and software “for integrating industrial processes”
- remove individuals and entities listed in Attachments 3 and 4 from the Specially Designated Nationals List, Foreign Sanctions Evaders list, Iran Sanctions Act List, and listed by E.O. 13382, E.O. 13608, E.O. 13622, and E.O. 13645
8.5 years after Adoption Day (March 2024)
- Iran may commence testing up to 30 advanced centrifuge machines. Iran will proceed from single centrifuge machines and small cascades to intermediate cascades in a logical sequence.
- Iran may begin manufacturing of IR-6 and IR-8 centrifuges without rotors through year 10 at a rate of up to 200 centrifuges per year for each type
Termination Day, 10 years after Adoption Day (October 2025)
- UNSC resolution endorsing JCPOA terminates, as does all UNSC consideration of the Iranian nuclear program
- EU terminates all remaining sanctions
- Iran’s obligation to keep its enrichment capacity below 5060 IR-1 centrifuges comes to an end
- Iran can also test large numbers of, and conduct enrichment R&D with, advanced centrifuges
- Iran can begin installing the necessary infrastructure for the IR-8 at Natanz in Hall B of FEP
- Iran can produce complete centrifuges at a rate of up to 200 a year
- Iran’s commitment that all uranium isotope separation-related R&D or production activities will be exclusively based on gaseous centrifuge technology ends
15 years after Adoption Day (October 2030)
- Iran’s obligation to export all heavy water beyond Iran’s needs for the modernized Arak research reactor ends
- Iran’s obligation to keep uranium enrichment below 3.67 percent and 300kg ends
- Iran’s obligation to conduct all testing of centrifuges with uranium at PFEP (Natanz) and all mechanical testing of centrifuges is only at PFEP and the Tehran Research Center ends
- Iran’s commitment not to conduct any uranium enrichment or related R&D at Fordow ends
- Iran’s commitment to limit the number, location and activity of IR-1 centrifuges in Fordow ends
- Iran’s obligation not to engage in any spent fuel reprocessing or related R&D activity, nor to acquire hot cells or facilities capable of separation of plutonium, uranium or neptunium from spent fuel ends. Iran “does not intend to thereafter” to resume these activities.
- Iran’s commitment not to acquire plutonium or uranium metals or conduct related R&D ends
- Iran’s commitment not to operate facilities for converting fuel plates or scrap back to UF6 ends
- Iran’s formal commitment to permit the IAEA on-line enrichment measurement and electronic seals, and to facilitate a long-term IAEA presence through visas, working space and an increased number of inspectors ends
- Iran’s commitment to allowing IAEA continuous monitoring of stored centrifuges and infrastructure ends
- Iran’s commitment to allowing the IAEA regular access to Natanz ends
- Iran’s commitment to obtain prior approval from the Joint Commission before engaging in enrichment or enrichment related activities with other countries ends
20 years after Adoption Day (October 2035)
- Iran’s commitment to contain, and allow IAEA surveillance of, rotor tubes and bellows ends
25 years after Adoption Day (October 2040)
- Iran’s commitment to permit IAEA verification that all uranium is transferred to the uranium conversion facility in Esfahan (or to future uranium conversion facilities which Iran might eventually build) ends
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Commentary
A comprehensive timeline of the Iran nuclear deal
July 21, 2015