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This is just a guess, but the temperature differential is going to be greater in the winter after the tires warm up. My current tires don't specify whether the max psi is hot or cold, but I've seen tires that specify it as the cold pressure. I have observed on our Jeep with the fancy tire pressure monitor during cold winter trips (0 F ambiant) running 80mph that our 44psi rated tires will increase 7-8 psi before it plateaus. I've observed in the summer (100 F ambiant) during the same trip the pressure only increases 3-5psi. (Kind of off topic: One time after parking in the sun I actually managed to get the psi to go DOWN by driving 35-40mph for a few minutes; I'm guessing it was because of the wind.)
All that might go straigh out the window when you consider that all season tires are run in the winter too, so take what you will.
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