{
    "type": "ETC",
    "ucits": false,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Physical Carbon EUA exposure",
        "Structured as debt security",
        "High risk rating (6/7)"
    ],
    "classification": "complex",
    "supporting_data": "The SparkChange Physical Carbon EUA ETC is structured as a debt security linked to physical EUAs, which introduces complexity due to its non-traditional asset class and regulatory framework. The high risk rating (6/7) indicates significant volatility and potential for loss, which may not be easily understood by retail investors. Additionally, the ETC's exposure to the carbon market, which is influenced by environmental policies, energy prices, and market stability mechanisms, adds layers of complexity. While it does not use derivatives or leverage, the underlying asset's complexity and the structured nature of the product warrant a 'complex' classification under MiFID II.",
    "confidence": 85
}