{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for limited portfolio management; no synthetic replication; no embedded derivatives",
    "classification": "non-complex",
    "supporting_data": "The Rize Circular Economy Enablers UCITS ETF is a UCITS-compliant ETF that primarily invests physically in the underlying companies of a transparent equity index (Foxberry SMS Circular Economy Enablers USD Net Total Return Index). It may use financial derivative instruments (FDIs) but only for limited purposes related to efficient portfolio management, not as an inherent part of the replication strategy. There is no indication of synthetic replication or embedded derivatives such as options or swaps integral to the ETF's objective. The ETF does not employ significant leverage beyond UCITS limits, nor does it have complex features like capital protection or illiquid underlying indices. The risk profile is high due to market volatility and exposure to small and micro-cap companies, but this does not imply structural complexity. The ETF's structure and risks are transparent and understandable to a retail investor with basic knowledge. According to MiFID II Article 254, Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, such a UCITS ETF with physical replication, limited derivative use for EPM, and transparent index tracking is classified as non-complex. This aligns with ESMA and industry views that UCITS ETFs without synthetic replication or embedded derivatives are non-complex. Therefore, no appropriateness test or comprehension alert is required under MiFID II for this ETF."
}