We give a new lower bound on the length of the minimal Steiner tree with a given topology joining given terminals in Euclidean space, in terms of toroidal images. The lower bound is equal to the length when the topology is full. We use the lower bound to prove bounds on the "error" e in the length of an approximate Steiner tree, in terms of the maximum deviation d of an interior angle of the tree from 120°. Such bounds are useful for validating algorithms computing minimal Steiner trees. In addition we give a number of examples illustrating features of the relationship between e and d, and make a conjecture which, if true, would somewhat strengthen our bounds on the error.