{
    "type": "ETC",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The iShares Physical Palladium ETC is a physically backed commodity product that directly holds palladium. The KIID and factsheet confirm it uses physical replication, with no mention of derivatives, swaps, or leverage. The risk indicator is high (6 out of 7), but this reflects the volatility of palladium prices rather than structural complexity. The product is transparent, with clear exposure to a single commodity, and does not involve complex strategies or instruments. The warning in the Spanish jurisdiction does not inherently indicate complexity under MiFID II but rather reflects local regulatory caution about commodity investments.",
    "confidence": 95,
    "risk_level": "high",
    "additional_notes": "While the product carries high risk due to commodity price volatility, it does not exhibit structural complexity under MiFID II criteria. The physical backing and straightforward exposure to palladium prices make it suitable for retail investors who understand commodity risk."
}