{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The iShares MSCI EM ex-China UCITS ETF USD (Acc) aims to replicate the MSCI Emerging Markets ex China Index by physical replication, holding the underlying equity securities in similar proportions to the index. The ETF is a UCITS fund, which under MiFID II Article 25(4)(a)(iv) is generally presumed non-complex. Although the fund may use financial derivative instruments (FDIs), these are used for direct investment purposes to gain exposure to certain securities (e.g., ADRs and GDRs) and for short-term securities lending to offset costs. The derivatives use is limited and not integral to the replication strategy, which is physical, not synthetic. There is no indication of embedded derivatives, leverage beyond UCITS limits, or complex structured products such as CLOs. The index tracked is transparent and straightforward, and the ETF's structure and risks (market volatility, tracking error) are easily understood by retail investors with basic knowledge. According to MiFID II and ESMA guidance, such a UCITS ETF with physical replication and limited derivative use for efficient portfolio management is classified as non-complex. Therefore, no appropriateness assessment is required for execution-only sales, and no comprehension alert is mandated."
}