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________________________________

June 22, 2026

VanEck ETF Trust

666 Third Avenue, 9th Floor

New York, New York 10017

Re: Opinion of Counsel regarding Post-Effective Amendment No. 2,946 to the Registration Statement filed

on Form N-1A under the Securities Act of 1933

(File Nos. 333-123257; 811-10325)

Dear Ladies and Gentlemen:

We have acted as counsel to VanEck ETF Trust (the “Trust”), in connection with the above-referenced

Registration Statement (as amended, the “Registration Statement”), which relates to the shares of

beneficial interest of the VanEck China Semiconductor ETF, no par value (collectively, the “Shares”).

This opinion is being delivered to you in connection with the Trust’s filing of Post-Effective Amendment

No. 2,946 to the Registration Statement (the “Amendment”) to be filed with the Securities and Exchange

Commission pursuant to Rule 485(b) under the Securities Act of 1933, as amended (the “1933 Act”), and

Amendment No. 2,950 pursuant to the Investment Company Act of 1940, as amended, in connection with

the effectiveness of the VanEck China Semiconductor ETF. With your permission, all assumptions and

statements of reliance herein have been made without any independent investigation or verification on our

part except to the extent otherwise expressly stated, and we express no opinion with respect to the subject

matter or accuracy of such assumptions or items relied upon. We have reviewed the Trust’s Amended and

Restated Declaration of Trust and such other documents and matters as we have deemed necessary to

enable us to render this opinion.

Based upon, and subject to, the foregoing, we are of the opinion that the Shares proposed to be sold

pursuant to the Amendment, when effective, will have been duly authorized and, when sold in accordance

with the terms of the Amendment and the requirements of applicable federal and state law and delivered by

the Trust against receipt of the net asset value of the Shares, will have been legally issued, fully paid and,

subject to the qualifications set forth in the Amended and Restated Declaration of Trust, non-assessable by

the Trust (except for the potential liability of shareholders described in the Trust’s current Statement of

Additional Information under the caption “Capital Stock and Shareholder Reports”). In this regard, we

note that, pursuant to Section 5.02 of Article V of the Amended and Restated Declaration of Trust, the

Trustees have the power to cause each Shareholder, or each Shareholder of any particular Series, to pay

directly, in advance or arrears, for charges of the Trust’s custodian or transfer, shareholder servicing or

similar agent, an amount fixed from time to time by the Trustees, by setting off such charges due from

such Shareholder from declared but unpaid dividends owed such Shareholder and/or by reducing the

number of Shares in the account of such Shareholder by that number of full and/or fractional Shares which

represents the outstanding amount of such charges due from such Shareholder.

We are attorneys licensed to practice only in the State of New York. The foregoing opinion is limited to

the Federal laws of the United States and the Delaware Statutory Trust Act, and we are expressing no

opinion as to the effect of the laws of any other jurisdiction.

June 22, 2026

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We have consented to the filing of this opinion as an exhibit to the Registration Statement and to the

reference to us under the headings “General Information” in the Prospectus and “Counsel and Independent

Registered Public Accounting Firm” in the Statement of Additional Information, each forming a part of the

Registration Statement. In giving this consent, we do not concede that we are in the category of persons

whose consent is required under Section 7 of the 1933 Act.

Very truly yours, 

/s/ Dechert LLP           

Dechert LLP