Down-regulation of leaf N and Rubisco under elevated CO2 (eCO2) are accompanied by increased non-structural carbohydrates (NSC) due to the sink-source imbalance. Here, to investigate whether the canopy position affects the down-regulation of Rubisco, we measured leaf N, NSC and N allocation in two species with different heights at maturity [Fraxinus rhynchophylla (6.8 ± 0.3 m) and Sorbus alnifolia (3.6 ± 0.2 m)] from 2017 to 2019. Since 2009, both species were grown at three different CO2 concentrations in open-top chambers: ambient CO2 (400 ppm; aCO2); ambient CO2 × 1.4 (560 ppm; eCO21.4); and ambient CO2 × 1.8 (720 ppm; eCO21.8). Leaf N per unit mass (Nmass) decreased under eCO2, except under eCO21.8 in S. alnifolia and coincided with increased NSC. NSC increased under eCO2 in F. rhynchophylla, but the increment of NSC was greater in the upper canopy of S. alnifolia. Conversely, Rubisco content per unit area was reduced under eCO2 in S. alnifolia and there was no interaction between CO2 and canopy position. In contrast, the reduction of Rubisco content per unit area was greater in the upper canopy of F. rhynchophylla, with a significant interaction between CO2 and canopy position. Rubisco was negatively correlated with NSC only in the upper canopy of F. rhynchophylla, and at the same NSC, Rubisco was lower under eCO2 than under aCO2. Contrary to Rubisco, chlorophyll increased under eCO2 in both species, although there was no interaction between CO2 and canopy position. Finally, photosynthetic N content (Rubisco + chlorophyll + PSII) was reduced and consistent with down-regulation of Rubisco. Therefore, the observed Nmass reduction under eCO2 was associated with dilution due to NSC accumulation. Moreover, down-regulation of Rubisco under eCO2 was more sensitive to NSC accumulation in the upper canopy. Our findings emphasize the need for the modification of the canopy level model in the context of climate change.