The Regulation defines in point 20 of Annex I standby mode as "a condition where the product is connected to the mains power source and provides only one or more of the following functions, which may persist for an indefinite time:
- reactivation function, or reactivation function and indication of enabled reactivation function
- reactivation function through a connection to a network (‘networked standby’);
- information or status display".
What is presented as so-called 'off' falls under the definition of stand-by, assuming the product can be re-activated. The fact that in such 'off' the control is working (and presumably consuming some energy) is precisely why standby is addressed in the regulation.
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.