EXHIBIT 5.1 - OPINION OF RAICE PAYKIN & KRIEG, LLP

                     [RAICE PAYKIN & KRIEG, LLP LETTERHEAD]

July 21, 2003
Action Products International, Inc.
390 N. Orange Ave., Suite 2185
Orlando, Florida  32801

         Re: Form S-3 Registration Statement

Ladies and Gentlemen:

         We have acted as counsel for Action  Products  International,  Inc.,  a
Florida  corporation,  (the  "Corporation"),  in connection  with the referenced
Registration Statement on Form S-3 (the "Registration Statement") being filed by
the Corporation with the Securities and Exchange  Commission (the  "Commission")
under the Securities Act of 1933, as amended,  and covering 60,000 shares of the
Corporation's  Common Stock,  $0.001 par value ("Common Stock"),  that have been
issued, or may be issued pursuant to the warrant, referenced in the Registration
Statement.  This Opinion Letter is rendered  pursuant to Item 16 of Form S-3 and
Item 601(b)(5) of Regulation S-K.

         We have examined the Articles of Incorporation  of the Corporation,  as
amended,  the Bylaws of the Corporation,  as amended,  records of proceedings of
the Board of  Directors of the  Corporation  deemed by us to be relevant to this
opinion letter, the Registration Statement and other documents and agreements we
deemed  necessary  for purposes of expressing  the opinion set forth herein.  We
also have made such further legal and factual examinations and investigations as
we deemed necessary for purposes of expressing the opinion set forth herein.

         As to certain factual matters relevant to this opinion letter,  we have
relied upon  certificates  and  statements  of officers of the  Corporation  and
certificates of public officials. We have made no independent investigation with
regard thereto,  and,  accordingly,  we do not express any opinion as to matters
that might have been disclosed by independent verification.

         This opinion letter is provided to the  Corporation  and the Commission
for their use solely in connection  with the  transactions  contemplated  by the
Registration  Statement.  The only  opinion  rendered  by us  consists  of those
matters set forth in the sixth paragraph  hereof,  and no opinion may be implied
or inferred beyond those expressly stated.

         We are admitted to practice law in the State of New York, and we render
this opinion only with respect to, and express no opinion herein  concerning the
application or effect of the laws of any  jurisdiction  other than, the existing
laws of the  United  States  of  America,  of the  State  of New York and of the
Business Corporation Act of the State of Florida and applicable case law.

         Based on the  foregoing,  it is our opinion  that the 60,000  shares of
Common Stock covered by the Registration  Statement to be issued pursuant to the
warrant referenced in the Registration Statement, when issued in accordance with
the terms and conditions of the warrant will be, legally issued,  fully paid and
non-assessable.

         We consent to the  filing of this  opinion  letter as an exhibit to the
Registration Statement and to the use of our firm name wherever appearing in the
Registration  Statement. In giving such consent, we do not thereby admit that we
are within the category of persons whose consent is required  under Section 7 of
the Securities Act or the rules and regulations of the Commission thereunder.

                                        Sincerely,

                                        /s/ RAICE PAYKIN & KRIEG, LLP