They allowed a safety zone due to dieseling and other possible reasons.
Hence why you get some airguns at 10ftlbs form some suppliers but some owners think that is too low.
From evidence from Bill Harriman at BASC.
https://publications.parliament.uk/pa/cm199900/cmselect/cmhaff/95/95ap80.htm Note the date of the evidence .
(1) The 12 ft/lb limit for air rifles is about the lowest energy level which is humane for controlling agricultural pests such as rabbits, crows etc. Air rifles whose energy value is near to this limit are very useful for shooting such pests, particularly in places where it would be dangerous or otherwise inappropriate to use a cartridge firearm. Such air rifles are capable of killing pests and small game humanely at ranges up to about 35m.
The aim of airgun manufacturers is to produce air weapons which are consistent in performance. This means that they will regulate their product to give optimal performance at a level below the legal maximum. This will incorporate a "safety zone" which is broad enough to keep energy levels away from the upper limit in the event that something causes the original energy level to rise. An example of this might be over-oiling the air gun which introduces oil into the air cylinder. This can cause "dieseling" and increased velocities and concomitant energy level rises. Another cause of increased energy levels can be the use of a lighter pellet. In my experience most manufacturers regulate energy limits for rifles at 10-10½ ft/lb. This gives an energy level which is humane for pest control, but which is not so close to the upper limit that it will exceed it if the level should rise for any reason.