I think that's a simple case of knowing what you are buying and reading the description properly.
The title simply says "Austrains HO Scale "Six LCL Containers"
And, nowhere in that listing does it mention an flat wagon as can be read by the following:
"AUSTRAINS LCL Container
Contains six containers in a pack
** All containers are well-packed in original box to prevent damage/broken, & they are all 100% new **
** More detailed pictures can be sent under request, just message me,thanks **
So I do not see where the problem is from a legal point of view in as far as the title or description being misleading.
Also, if you knew that the actual flat wagons are about $195 for three or roughly $65.00 each, you may have a good look as to why they are less than half price. If you didn't know the real value then I guess you may not think about the price being low.
I agree that it would be better to show a picture of the six LCL containers by themselves to make it clear from an illustration point of view, but once again pictures are not always of the actual item and that's something to be aware of especially where new items are concerned.
Bottom line is you need to very carefully read any descriptions on Ebay, and if in doubt ask the seller a question. Also if it seems like a deal too good to be true, it probably is!