Dearly beloved, we are gathered to read from the directive.

First quote:
"(11) In order to prevent unnecessary losses of energy, products should
ideally enter into a "0-Watt" consumption state when providing no function.
The technical feasibility and appropriateness should be considered on a
product-by-product basis in the relevant implementing measure pursuant to
Directive 2005/32/EC."

So I make the inference is that the device has a mechanical disconnect that
opens the connection from mains to interrupt all ac current flow to the device.

Second quote:
'''6. "off mode" means a condition in which the equipment is connected to the
mains power source and is not providing any function; the following shall also
be considered as off mode:
(a) conditions providing only an indication of off-mode condition;
(b) conditions providing only functionalities intended to ensure
electromagnetic compatibility pursuant to Directive 2004/108/EC of the
European Parliament and of the Council [2];'''

So I then make the the assumption that current flow from mains is not
interrupted for 'off' mode; and that this 'off' mode is a lower power
consumption mode than 'standby'.

Third quote:
"Off mode : 0 W-0,3 W with hard-off switch on the primary side, depending,
inter alia, on the characteristics related to electromagnetic compatibility
pursuant to Directive 2004/108/EC."

Finally, I note that the 'off' mode does, in fact, require a mechanical
disconnect from mains. And note the 'inter alia' - so this means that I get to
make this up as I go ?

Oh, do not forget the section that says that there can be yet another,
non-named mode, when standby or off is not appropiate - left as an excercise
for the reader to find...

Brian 

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