Baryogenesis at the TeV scale from $CP$-violating decays of a massive particle requires some way to avoid the washouts from processes closely related to the existence of $CP$ violation. Baryogenesis from three-body decays (instead of two-body decays) has been proposed as a way for TeV scale baryogenesis. In this work we revisit this statement and show that, although three-body-decay models can provide interesting alternatives to address other kind of difficulties faced by low-scale baryogenesis, the generic problem due to the washouts proportional to the $CP$ asymmetry persists. Therefore, as in two-body-decay models, the mass of the decaying particle cannot be below $\sim 10\mathrm{TeV}$ unless some mechanism to avoid these kinds of washouts is implemented.