In this study, theoretical limits are obtained for the accuracy of range (distance) estimation in visible light positioning (VLP) systems. In particular, the Ziv-Zakai bound (ZZB) and the weighted Cramer-Rao bound (WCRB) are derived ´ for range estimation based on received signal strength (RSS) measurements. Also, the maximum a posteriori probability (MAP) and the minimum mean-squared error (MMSE) estimators are obtained for RSS based range estimation, and compared against the theoretical limits.