This was about the same time they stopped shipping things in cardboard boxes and went with bubble packs, and most recently, paper wrap with no padding whatsoever.
Other things however come just as you would expect (paper wrapping or bubble wrapped). So it all depends on the amazon worker doing his or her job..
Basically, you choose why you're returning. In some cases if you say something other than "the item was defective", it'll only have options that cost money.
It's super rare, but I've seen it before.