The deaths all occurred in Herat and Kabul provinces during the first two weeks of January, information received by Amnesty International indicated.
The organization, based in London, said community leaders in the two provinces criticized the Afghan government and international aid agencies for inconsistent and inadequate levels of food and fuel assistance.
"The fact that children and the elderly are among the dead highlights the need to protect those groups that are most vulnerable to harsh winter conditions," said Polly Truscott, Amnesty International's deputy director for Asia-Pacific.
Truscott called the deaths "a preventable tragedy."
Last winter more than 100 people, mostly children, died in displacement camps as a result of harsh weather conditions.