If the pi is designed to throttle at a temperature where its lifespan is reduced from 50 to 49 years, then it is throttling at a gratuitously low temperature that affects quite a few use cases.
On the other hand, if it is designed to throttle at a temperature that materially reduces the lifespan, then it needs a fan to preserve its lifespan.
Either way, the hardware is starkly suboptimal for a pretty large set of advertised use cases until you add a fan.