{
    "name": "First Trust Nasdaq Clean Edge Green Energy UCITS ETF",
    "isn": "IE00BDBRT036",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track the Nasdaq Clean Edge Green Energy IndexSM, with no evidence of leverage, inverse strategies, or synthetic replication. The risk profile (SRRI 7) is high due to market volatility but does not indicate structural complexity. The fund holds liquid equities and does not employ derivatives beyond standard Efficient Portfolio Management (EPM) practices. The KIID and factsheet confirm a straightforward index-tracking strategy with full physical replication.",
    "confidence": 95,
    "risk_level": 7,
    "counter_argument": "While the SRRI is high (7), this reflects market risk rather than structural complexity. The fund's exposure to Chinese VIEs introduces geopolitical risk, but this does not constitute complexity under MiFID II. The absence of derivatives, leverage, or synthetic replication supports the non-complex classification.",
    "final_decision_override": "The fund is classified as non-complex because its structure and strategy are transparent and align with standard UCITS ETF practices, despite the high-risk profile."
}