Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549

         Re:      Tech Laboratories, Inc.
                  Registration Statement on Form SB-2
                  Filed with the Securities and Exchange Commission
                  on August 3, 2004
                  (Registration No. 333-117899)
                  Request for Withdrawal

Ladies and Gentlemen:

Pursuant to Rule 477 promulgated under the Securities Act of 1933, Tech
Laboratories, Inc. (the "Company") hereby applies for the withdrawal of its
registration statement on Form SB-2, File No. 333-117899, which was filed on
August 3, 2004 (the "Registration Statement").

The reasons for the withdrawal of the Registration Statement are as follows: the
Company was required to restate its financial statements as the independent
auditor for the Company was not registered with the Public Company Accountants
Oversight Board. The Company subsequently ceased its previous business
operations and is currently looking for another business opportunity.

No sales of any of the Company's securities have been completed and the
Registration Statement has not been declared effective by the Commission.
However, the Company may undertake a private offering in the future in reliance
on Securities Act Rule 155(c).

Should you have any comments please contact our legal counsel, Gregg E. Jaclin
at (732) 409-1212.

Very truly yours,

TECH LABORATORIES, INC.


By:      /s/ Donna Silverman
         -------------------
         Donna Silverman
         President