This condition is not considered as being "standby", because it is an extra function and the condition does not last for an indefinite time. As soon as the oven has cooled down the fan is switched off.
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.