I do not think PayPal has changed there policy on shipping to unconfirmed addresses, info from PayPal is below:
QUOTE
Seller Protection Policy (part of)
Item is shipped to an eligible address.
For your transaction to qualify, you must ship the item to an eligible address. PayPal is continually working to increase the number of eligible buyer addresses. To determine shipping address eligibility, refer to the shipping address area of your Transaction Details page.
I know with Express orders if the address is not confirmed your transaction record will show that you are ineligible for the Seller Protection.
Also if you choose to send the item anyways and the customer then files they never received it, more than like even with the proof you sent it and they received it, you generally will not win the case. This is not fair for sellers and I think when customers open paypal accounts it should be a requirement to verify your address before you can make purchases. Just my 2 cents.