{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for index replication and risk management; exposure to structured products like CLOs",
    "classification": "complex",
    "supporting_data": "The VanEck Sustainable Future of Food UCITS ETF aims to replicate the MVIS Global Future of Food ESG Index primarily through physical replication by investing directly in underlying equity securities. However, it also uses financial derivative instruments (FDIs) such as futures, options, and swaps (including equity swaps and index swaps) related to the index or its constituents. The use of these derivatives is integral to achieving the investment objective and not solely for efficient portfolio management, introducing counterparty and collateral risks that are difficult for retail investors to understand. Additionally, the Fund may invest in structured products like Collateralized Loan Obligations (CLOs), which are complex structured debt instruments embedding derivatives and complex payout structures. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, while UCITS are generally presumed non-complex, exceptions apply for structured UCITS or those investing significantly in derivatives or structured products. Such ETFs fail the non-complex criteria due to embedded derivatives, potential leverage, and complexity of underlying assets, requiring an appropriateness assessment under MiFID II. ESMA and CESR guidance confirm that synthetic replication, embedded derivatives, and structured products like CLOs render a UCITS ETF complex. Therefore, despite the UCITS label and physical replication, the integral use of derivatives and exposure to CLOs classify this ETF as complex under MiFID II.",
    "final_assessment": "Complex"
}