User blog comment:Xilinoc/Ch. 567 (Rukia be like "I ain't even scared though")/@comment-10554972-20140205203959/@comment-5693502-20140206001019

Technically it's not an Ice-type because it doesn't produce ice. The only reason ice is associated is because of how prevalent water is in the atmosphere (and as we all know, frozen water = ice). She's just freezing whatever's in her vicinity.

After all you can have cold without ice, but you can't have ice without cold (hot ice does not count).