“Diminishing returns” in leaf economics occurs when increases in lamina mass (M), which can either be represented by lamina dry mass (DM) or fresh mass (FM), fail to produce proportional increases in leaf surface area (A), such that the scaling exponent (α) for the M vs. A scaling relationship exceeds unity (i.e., α > 1.0). Prior studies have shown that FM vs. A is better than DM vs A in assessing diminishing returns in evergreen species. However, the superiority of FM vs. A over DM vs. A has been less well examined for deciduous species. Here, we applied reduced major axis protocols to test whether FM vs. A is better than DM vs. A to describe the M vs. A scaling relationship, using a total of 4271 leaves from ten deciduous and two evergreen tree species in the Fagaceae and Ulmaceae for comparison. The significance of the difference between the scaling exponents of FM vs. A and DM vs. A was tested using the bootstrap percentile method. Further, we tested the non-linearity of the FM (DM) vs. A data on a log-log scale using ordinary least squares. We found that (i) the majority of scaling exponents of FM vs. A and DM vs. A were >1 thereby confirming diminishing returns for all 12 species, (ii) FM vs. A was more robust than DM vs. A to identify the M vs. A scaling relationship, (iii) the non-linearity of the allometric model was significant for both DM vs. A and FM vs. A., and (iv) the evergreen species of Fagaceae had significantly higher DM and FM per unit area than other deciduous species. In summary, FM vs. A is a more reliable measure than DM vs. A when dealing with diminishing returns, and deciduous species tend to invest less biomass in unit leaf light harvesting area than evergreen species.