Surely this mean that any item sold with Paypal can be charged back no matter what it is??
yep. even better. even item delivered but buyer claim difference between item and description is enough to get money back.
easiest way...stay away from payhell.
Surely there must be an easy to produce item that cant be claimed back.
Like asking for a plain white png image 500x500, and a proved received confirmation of the image, with a description.