With academic internationalisation at full speed, English is increasingly used as a medium of instruction in higher education. The question arises of whether unbalanced bilinguals remember study materials in a non-native language (L2) as well as in a first language (L1). In previous studies, we found a disadvantage for students recalling short, expository texts in L2 compared with L1, but no such disadvantage for a true/false recognition test, not even on delayed tests after a month. As no additional forgetting occurs, the quality of the memory trace seems to be equally strong in both languages and the recall cost might be caused by a lack of production skill in L2. To test this hypothesis, we ran experiments in L1–L1, L2–L1, and L2–L2 conditions with free and cued recall (short open questions). We replicate the L2 free recall cost reported earlier and show that it is due to the encoding in L2 rather than to an L2 production cost. In contrast, we found no significant difference in a new pair of texts with short, cued recall questions, though there was a trend in the expected direction. A summary of the effect sizes obtained so far shows a considerable variety in magnitudes (with rather big confidence intervals), suggesting that the cost of studying in L2 depends on several factors such as study time, test requirement, and language proficiency level.