Because the drives come back to the manufacturer in an unknown state with the heads/actuator unparked (assuming the drive has been powered-up at least once). The non-operating shock tolerance figure for drives with unparked heads/actuators is something like 1/3 of that for parked.Then explain as to why manufacturers are VERY specific on packaging RMAs and if you don't follow their guidelines to a T your warranty claim is null and void? The explicitly say NO PEANUTS!
Packing peanuts retain or shed lots of particulate matter and dust as well, and people don't always send the drive back in a well-sealed antistatic bag.
If surrounded by a reasonable thickness of bubble wrap, the drive is never vulnerable even when it settles to one side of the box. Vulnerable to what, someone whacking the box with a hammer exactly where the drive has settled?
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