Ditto what Tom said.
Also, the rule of thumb for overwintering--the more soil volume around the roots, the more protection the roots have. That applies from in-ground, bed grown and containerized trees. It doesn't really have anything to do with the roots' proximity to the ground. It has to do with how much soil is around the roots.
For instance, I have a big live oak bonsai in a 15 gallon or so pot. I have another smaller one in a pot that holds maybe 2 gallons. The big tree is entirely winter hardy and has shown little, if any, problems with overwintering in temps down to zero or so in a cold frame. The smaller one, however, consistently dies back to the trunk every year. The difference is simple soil volume--larger mass retains more heat for longer than a smaller mass...
That means, how big are your growing beds? If they hold hundreds of gallons of soil and the trees are in the middle of that mass, you probably don't have to worry.