Exhibit 8.1

                         [LETTERHEAD OF BLANK ROME LLP]

                                                          August 26, 2003

Hudson Technologies, Inc.
275 North Middletown Road
Pearl River, New York 10965


Gentlemen:

      We have acted as counsel to Hudson Technologies, Inc (the "Company") in
connection with its proposed distribution, to stockholders of record on August
1, 2003, of rights to purchase (the "Rights") shares of common stock, par value
$.01 per share (the "Common Stock") of the Company (the "Rights Offering").

      You have requested our opinion as to the material United States federal
income tax consequences of the distribution of the Rights in the Rights Offering
to stockholders of the Company who are United States citizens. In preparing our
opinion, we have reviewed and relied upon the Company's Registration Statement
on Form SB-2 (File No. 333-105128), as amended (the "Registration Statement"),
and such other documents as we deemed necessary.

      The opinion set forth below does not address the tax consequences of the
distribution of the Rights in the Rights Offering under applicable state, local
or foreign tax laws. Moreover, the opinion does not address every aspect of
taxation that may be relevant to a particular taxpayer under special
circumstances or who is subject to special treatment under applicable law and is
not intended to be applicable in all respects to all categories of investors.
Other tax considerations may apply to investors who are, for example, insurance
companies, tax-exempt persons, financial institutions, regulated investment
companies, dealers in securities, persons who hold their shares of Common Stock
as part of a hedging, straddle, constructive sale or conversion transaction,
persons whose functional currency is not the U.S. dollar and persons who are not
treated as a U.S. stockholder.

      On the basis of the foregoing, it is our opinion that the distribution of
the Rights to the Company's stockholders who are United States citizens should
not be a taxable transaction.

      The opinion set forth above is based upon the applicable provisions of the
Internal Revenue Code of 1986, as amended, the Treasury Regulations promulgated
or proposed thereunder, current positions of the Internal Revenue Service (the
"IRS") contained in published revenue rulings, revenue procedures and
announcements, existing judicial decisions, and other applicable authorities. No
tax rulings have been or will be sought from the IRS with respect to any of the
matters discussed herein. Unlike a ruling from the IRS, opinions of counsel are
not binding on the IRS. Hence, no assurance can be given that the opinion stated
in this letter will



Hudson Technologies
August 26, 2003
Page 2


not be successfully challenged by the IRS. We express no opinion concerning any
United States federal income tax consequences of the Rights Offering except as
expressly set forth above.

      We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the summarization of this opinion under the
section titled "Income Tax Effect of Exercising Subscription Rights" in the
Registration Statement.

                               Very truly yours,


                               /s/ BLANK ROME LLP

                               BLANK ROME LLP