{
    "type": "ETC",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication",
        "Swap usage",
        "Commodity futures exposure"
    ],
    "classification": "complex",
    "supporting_data": "The WisdomTree Cotton - EUR Daily Hedged ETC is classified as complex under MiFID II due to several key factors: 1) Synthetic replication via swaps (evidenced by 'total return exposure to Cotton futures contracts' and 'fully collateralised' structure), 2) Exposure to commodity futures (which are derivatives), and 3) The ETC's reliance on rolling futures contracts (which introduces roll costs and contango/backwardation effects). While the product is UCITS-eligible and has a straightforward risk profile (5/7), the use of derivatives for replication rather than physical holding of cotton futures triggers complexity under MiFID II. The PRIIPs KID's 'comprehension warning' further supports this classification. The monthly factsheet would likely confirm swap usage and futures rolling strategy, reinforcing the complexity determination.",
    "confidence": 90
}