The option of an evaluation and assessment of possible sublethal effects of pesticides on bees has been a subject of discussion by scientists and regulatory authorities. Effects considered included learning behaviour and orientation capacity. This discussion was enhanced by the French bee issue and allegations against systemic insecticides that were linked to the hypothesis that sublethal intoxication might even have led to reported colony losses. This paper considers whether and, if so, how sublethal effects should be incorporated into risk assessment, by addressing a number of questions: What is meant by a sublethal effect? Which sublethal effects should be measured, when and how? How are sublethal effects to be included in risk assessments? The authors conclude that sublethal studies may be helpful as an optional test to address particular, compound-specific concerns, as a lower-tier alternative to semi-field or field testing, if the effects are shown to be ecologically relevant. However, available higher-tier data (semi-field, field tests) should make any additional sublethal testing unnecessary, and higher-tier data should always override data of lower-tier trials on sublethal effects.