In this announcement we see:
Buyers prevented from opening cases too soon
Additional checks will be in place to ensure a reasonable window of time for delivery before a buyer can open an eBay Buyer Protection case for an item not received or item not as described. When you upload tracking information and delivery is confirmed, buyers will not be able to open a case for item not received.
However, we have seen several reports lately like this one:
I had one filed 2 weeks ago on a Monday after they paid on the Friday before.
I don't believe the promised protection is effective, or maybe there are some gotchas involving where the shipping label was purchased, or something else not explained very well.
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