The response of mesophyll conductance to CO(2) (g(m)) to environmental variation is a challenging parameter to measure with current methods. The 'variable J' technique, used in the majority of studies of g(m), assumes a one-to-one relationship between photosystem II (PSII) fluorescence and photosynthesis under non-photorespiratory conditions. When calibrating this relationship for Populus trichocarpa, it was found that calibration relationships produced using variation in light and CO(2) were not equivalent, and in all cases the relationships were non-linear-something not accounted for in previous studies. Detailed analyses were performed of whether different calibration procedures affect the observed g(m) response to CO(2). Past linear and assumed calibration methods resulted in systematic biases in the fluorescence estimates of electron transport. A sensitivity analysis on modelled data (where g(m) was held constant) demonstrated that biases in the estimation of electron transport as small as 2% (∼0.5 μmol m(-2) s(-1)) resulted in apparent changes in the relationship of g(m) to CO(2) of similar shape and magnitude to those observed with past calibration techniques. This sensitivity to biases introduced during calibrations leads to results where g(m) artefactually decreases with CO(2), assuming that g(m) is constant; if g(m) responds to CO(2), then biases associated with past calibration methods would lead to overestimates of the slope of the relationship. Non-linear calibrations were evaluated; these removed the bias present in past calibrations, but the method remained sensitive to measurement errors. Thus measurement errors, calibration non-linearities leading to bias, and the sensitivity of variable J g(m) hinders its use under conditions of varying CO(2) or light.