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This review suggests that a passive heatsink should be sufficient to prevent throttling (probably with a caveat that it's not in an enclosure):

I know about the Raspberry 4:

But this thing has less surface!

I don't understand how it can be legal for the foundation to sell this without a heatsink!

I dont understand by what law they could be forced to sell this with a heatsink.

You mean like all the higher end CPUs that don't come with one either... gasp the insanity!