shipping overseas using paypal

I recently had a very bad experience shipping overseas without a tracking number. I sold a bottle of oud oil to a buyer in UK and provided him with the option to get a shipping method of his choice. I sent him an invoice and clearly mentioned that I cannot take responsibility of lost or damaged items. Buyer said he did not want to spend extra money to get tracking number. I send him pictures of the package and the receipt from the post office showing his package was shipped. After few days buyer filed a dispute on paypal that he has not received his item. I called paypal and told them I have email log of our conversation and buyer understood terms and conditions.

Paypal told me that IF BUYER DOES NOT RECEIVE HIS ITEM HE IS GONNA WIN THE DISPUTE REGARDLESS OF THE TERMS AND CONDITIONS. Even if I have shipped using a tracking number and package is lost in customs, it is seller's fault.

I want to share this with all of you so the you know that paypal is very biased and if you get dishonest buyer, you can get ripped very easily.
so in future I have decided not to ship anything overseas.