Exhibit 5
                     [Letterhead of Hogan & Hartson L.L.P.]

                                  June 5, 2002



Board of Directors
Central European Distribution Corporation
1343 Main Street, Suite 301
Sarasota, Florida 34236

Dear Gentlemen:

                  We are acting as counsel to Central European Distribution
Corporation, a Delaware corporation (the "Company"), in connection with its
registration statement on Form S-3 (the "Registration Statement"), filed with
the Securities and Exchange Commission relating to the proposed public offering
of up to 800,000 shares of the Company's common stock, par value $0.01 per
share, all of which shares (the "Shares") may be sold by certain selling
shareholders (each a "Selling Shareholder"). This opinion letter is furnished to
you at your request to enable you to fulfill the requirements of Item 601(b)(5)
of Regulation S-K, 17 C.F.R. (S) 229.601(b)(5), in connection with the
Registration Statement.

                  For purposes of this opinion letter, we have examined copies
of the following documents:

                  1. An executed copy of the Registration Statement.

                  2. The Certificate of Incorporation of the Company, as
                     certified by the Secretary of the Company on the date
                     hereof as being complete, accurate and in effect.

                  3. The Bylaws of the Company, with amendments thereto, as
                     certified by the Secretary of the Company on the date
                     hereof as being complete, accurate, and in effect.

                  4. Resolutions of the Board of Directors of the Company
                     adopted on January 17 and April 30, 2002, as certified by
                     the Secretary of the Company on the date hereof as being
                     complete, accurate, and in effect, relating to, among other
                     things, the original issuance of the Shares and
                     arrangements in connection therewith.

                  In our examination of the aforesaid documents, we have assumed
the genuineness of all signatures, the legal capacity of all natural persons,
the accuracy



and completeness of all documents submitted to us, the authenticity of all
original documents, and the conformity to authentic original documents of all
documents submitted to us as copies (including telecopies). This opinion letter
is given, and all statements herein are made, in the context of the foregoing.

                  This opinion letter is based as to matters of law solely on
the Delaware General Corporation Law, as amended. We express no opinion herein
as to any other laws, statutes, ordinances, rules, or regulations. As used
herein, the term "Delaware General Corporation Law, as amended" includes the
statutory provisions contained therein, all applicable provisions of the
Delaware Constitution and reported judicial decisions interpreting these laws.

                  Based upon, subject to and limited by the foregoing, we are of
the opinion that the Shares are validly issued, fully paid, and nonassessable.
In rendering the foregoing opinion, we have assumed the receipt by the Company
of the consideration specified in the resolutions of the Board of Directors of
the Company authorizing the original issuance and sale of the Shares.

                  This opinion letter has been prepared for your use in
connection with the Registration Statement and speaks as of the date hereof. We
assume no obligation to advise you of any changes in the foregoing subsequent to
the delivery of this opinion letter.

                  We hereby consent to the filing of this opinion letter as
Exhibit 5 to the Registration Statement and to the reference to this firm under
the caption "Legal Matters" in the prospectus constituting a part of the
Registration Statement. In giving this consent, we do not thereby admit that we
are an "expert" within the meaning of the Securities Act of 1933, as amended.

                                                    Very truly yours,

                                                    /s/ Hogan & Hartson L.L.P.

                                                    HOGAN & HARTSON L.L.P.