Plants have been developed as an alternative platform for the production of biopharmaceutical proteins, culminating recently with the FDA approval of the first plant-derived recombinant pharmaceutical enzyme for human use (ELELYSOÔ by Protalix Biotherapeutics). Among the many different plant-based technologies that have been proposed, transient expression mediated by Agrobacterium tumefaciens has proven to be particularly suitable for the rapid production of vaccines in response to emerging pandemics. However, one potential drawback of transient expression in whole plants is the large variation in recombinant protein expression levels among different leaves, which introduces a level of uncertainty in process design that can increase the regulatory burden and production costs. Transient expression is also used to test expression constructs prior to the longer and more expensive process of generating transgenic plants, and here the variation can produce misleading results leading to erroneous conclusions about the relative activity of different promoters and other regulatory elements. Such variation can be caused by loosely controlled environmental and process factors such incubation temperature, plant characteristics and the method and timing of harvesting. Here we discuss differences between transgenic plants and transient expression in intact plants, and their specific pitfalls for model building. We also highlight which aspects researchers should consider when using a DoE approach to investigate protein expression in plants, both for fundamental research and process development.