No its not. read the quote above (I emphasized the clues in anticipation of responses as yours)
Appears to be a bit of a childish response. If you'd already done your research why bother posting? As you have looked into it, you are aware of the frost wording. As such it would be practically impossible to drive in winter in Germany and ensure that you won't have frost.
It's therefore obvious that if you drive on summers in winter in Germany you will risk getting the fine if caught, and double the fine if you caused an issue by your actions.