EIOPA shall apply the following criteria and factors in considering the degree of innovation of the PEPP or of an activity or of a practice:
((a))
the degree of innovation related to the structure and features of the PEPP, in particular the degree of innovation of the risk-mitigation techniques or of the forms of out-payments or of the design of other PEPP benefits;
((b))
the extent of innovation diffusion, including whether the PEPP is innovative for particular categories of PEPP savers;
((c))
innovation involving leverage;
((d))
the past experience of the market with similar PEPPs or selling practices for PEPPs.