Keep in mind how many Points you get in which amount of time.
Let's make a calculation.
A CoH2 commander costs 15.000 loot points (I might be wrong, I am at work, but let's assume it this way).
You need to win three games to get a crate of 500 loot points (let's also assume that you are a pretty good CoH2 player and win every single game you play; ALSO you are a unlucky mofo that never gets anything out of crates but loot points, no skins or anything).
A game takes about 40 minutes of time to finish, most games are longer, but others are much shorter.
To get 500 Loot Points it takes you:
In order to buy yourself a commander it takes you:
Keep in mind that this is just a calculation of a perfect (in terms of crate drops and wins) calculation.
If we keep it realistic and say that you really are a good player and win 3 out of 4 games:
So a very good player needs 75 hours (more than 3 days!) of consequent CoH2 gaming to get one single commander for one single faction, which is insane.
Sure, as a CoH2 veteran you get Loot from double bulletins and stuff you could salvage from the past, but a new CoH2 player has nothing to salvage and starts with 0 Loot. And since as good as all "good" commanders that are meta are not available from the start, it is hard for him to compete because he gets stomped by those "better" commanders OR maybe he thinks about that 3$ are not the world and decides to buy himself a "good" commander.
It still simply is pay to win. You either pay real money to keep yourself competitive or you pay more than 70 real hours for those 3$, which is an hourly wage (hahaha) of about 0.04$. As someone with a job, I maybe get about 5-8 hours a week to play CoH2 in the evening, so it would take me about 10 weeks or 3 months to get a commander. And from my experiences, this timespan is pretty accurate.
Let's be real though, many players will simply abandon the game. Personally I would never, EVER pay for some ingame bullshit that gives me better chances to win. I bought WFA and the Brits, that's it.
Solid Maths right there, however I still don't consider it P2W since the system is not either fork over money or die until the RNG god smiles upon you, now you sort of can grind to it, like in F2P games.
Plus you could get up to 250000 points combined from all of the recent loot point events for the Winter Balance Patch, that is, if you could have fucking downloaded it thanks to Relic's brilliant download system.