I thought the panel temp was what counted, not the ambient temp. ISTR panel temps are usually 20C or whatever higher than ambient
It must take a while in the sun to heat up the panel though. When I took my readings soon after taking the panel outside to ambient 15C, the glass was not hot (yet)
Where we camp, even if it is hot out (90F) there is usually a cool breeze off the sea, plus the panel is propped up so there is no trapped air under it like a flat roof mounting.
I don't know how they can test at 25C. I guess they use a lamp for light that does not heat up the panel like the sun does.