I'm certainly no expert, but I think it has to do with the temperature differential the system is designed for, and the ambient temps it is expected to encounter.
For example, let's say an indoor refrigerator is designed to work in an ambient temp of 60F-80F, and provide a temperature differential of 40 degrees F between the outside of the box and the inside. We would expect it to be able to provide an inside temperature between 20F and 40F depending on the temperature outside the box.
Now, if you put that unit in a 20F environment and expect it to maintain a 40F temp, it would have to be working as a heater, which it is not designed to do.
I think it would need a different condenser design and possibly a different refrigerant to allow operation in the lower temperature ranges. I have heard that heat-pump type heaters don't work when the temperature gets below a certain point (my frigid office last month would be an example), and I suspect this would be a similar issue, only in reverse.
Of course, there is no doubt I don't know what I am talking about, and await the real answer from someone knowledegable in this area.