Low temperature has a tendency to retard chemical processes. If a cell was nothing but chemical, the reasoning would be sound. However, a cell is also a physical container to seal or contain the reactive chemicals made of materials that respond to temperature. As the materials of the container warm they expand. As they cool, they contract. In extreme temperatures there is a corresponding extreme expansion or contraction. Since they are made from differing materials, constructed in a manner to act as a seal for containment of the reactive chemicals, the expansion rate of the materials are dissimilar. As a result, extreme temperatures act on the different materials making up the sealed container just like a bi-metal thermometer works. The materials expand differently and as a result cause a shape distortion in the materials. The result could be a compromised seal that can no longer insure the containment of the reactive chemicals.
Those factors could be considered in the manufacture of cells, but I wouldn't trust it to be the case unless the manufacture specifically states that they are operative in sub-freezing temperatures.