EXHIBIT 5.2



                                                              April 5, 2002
Tech Laboratories, Inc.
955 Belmont Avenue
North Haledon, NJ 07508

Stursberg & Veith
405 Lexington Avenue
Suite 4949
New York, New York  10174-4902

Gentlemen:

         We have been asked to review the certificate of incorporation, as
amended (the "Certificate of Incorporation"), and the existing by-laws of Tech
Laboratories, Inc. (the "Company"). We have also reviewed such other documents
as we have deemed necessary and appropriate.

         We are aware that the Company is registering, pursuant to a
registration statement filed on Form SB-2, 17,103,236 shares of common stock,
par value $.01 (the "Shares"), of which up to 16,415,736 Shares may be sold upon
conversion of convertible notes, up to 412,500 Shares may be sold upon the
exercise of warrants issued in connection with the convertible notes, and the
remaining 275,000 Shares may be sold upon exercise of warrants unrelated to the
aforementioned convertible notes. We further advise that we are admitted to
practice law in the State of New Jersey.

         In reviewing the Certificate of Incorporation, by-laws and such other
documents as we have deemed necessary, we have relied on photostatic copies as
true and correct copies of all original documents.

         On the basis of such investigation as we have deemed necessary, we are
of the opinion that:

         1. The Company has been duly organized and is validly existing as a
corporation in good standing under the laws of the State of New Jersey.

         2. The Shares have been duly authorized and, when issued and fully paid
for, will be legally issued and non-assessable.

                                                Very truly yours,



                                                /s/ J. Howland Robinson