[Autumn]

I think that currently Frozen might be a bit of an abuse-able status effect, on top of being an immobilizing effect which is strong on its own, it also reduces evade to 0 for its entire duration, while the LV is lowered upon being hit or struggling, the amount of frozen tied to skills like Frigid Arrow and Icicle Spear nearly make these worth spamming all on their own. On top of this you can chain CC people still if you were to have access to immobilize as well as Frozen.

It almost essentially boils down to a checklist where if you do not have a solve to frozen you're as good as dead, mostly only if you relied on evade as your form of defense, while I'm usually the one to say that evade is fine in most scenarios where its specifically countered, this one in particular is very harsh on the target.

To summarize a little bit, here are the current outlying strengths of Frozen as a status:

-Immobilizing effect, creating a wall in which only mages may pass through uninhibited, Bonders and DH to a very certain extent.
-Sets evade to 0 for the entire duration
-Aside from FCR there is no status infliction involved in applying massive levels of Frozen.

All of this together it seems to be a very powerful status, and I'd love for it to stay that way, but its current counterplay amounts to suffering hits or popping a cleanse potion, struggle barely does anything to extremely high levels of frozen currently.

I think one good idea for Frozen as a status is to not have it reduce your evade to 0, but instead reduce your evade by it's LV instead, as it can be really silly that a lvl 15 Frozen from something like Freezing Crystal Rose opens you up to abuse from anything that evade was supposed to help against initially, such as dangerous on-hits and crits like Narcus/Skullcaver/Anchor Edge etc.

But this change would keep the lv200 and lv300 of Icicle Spear and Frigid Arrow impactful initially, but also make it so that struggling is eventually doing something in the long term of its duration, struggling and not breaking the frozen is a pointless waste of momentum otherwise.

[Snake]

While it doesn't make sense for the status to not lower Evade to 0, as you are frozen shut in place. I do agree with low level Frozens being hilarious and fairly overpowered.
(An additional condition to lower Evade to 0 is requiring Frozen to be atleast LV100+, this would address the 'nonsense' part of my concerns fairly easily. The fact you can't move is good enough a benefit for using low level versions of it.)

Struggle definitely needs to be (Scaled Strength * 2), and/or have a Trait tied to doing more damage to Frozen LV through the use of the skill. It's not doing the cut 99% of the time, even if you invest in STR, or even hardcap it. The fact you need to invest momentum on that should be rewarded a little more.