This condition is not considered as being "standby", because they do not last for an indefinite time. Examples of transitory power consumption states are start delay timers, cooling down phase for ovens.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.