Abstract-We highlight an essential difference between path-following and reference-tracking for non-minimum phase systems. It is well-known that in the reference-tracking, for non-minimum phase systems, there exists a fundamental performance limitation in terms of a lower bound on the L 2 -norm of the tracking error, even when the control effort is free. We show that this is not the case for the less stringent path-following problem, where the control objective is to force the output to follow a geometric path without a timing law assigned to it. Furthermore, the same is true even when an additional desired speed assignment is imposed.