This condition is not considered as being "standby", because it is part of the active mode of the device, able to save a considerable amount of energy if compared to the always on case.
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.