So you sell more than 19 a month, big deal, so the small seller who accidentally forgets to upload 1 tracking can just suck it up.  Its not a case of not being bothered it's a case of just missing 1 tracking item and being penalised.  eBay should have limits in place to protect small sellers, the same as they do for maximum number of allowed cases, ie 95% and 2 tracking not uploaded before Holds apply.