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                                                                     EXHIBIT 8.1
                      [SIDLEY & AUSTIN LETTERHEAD]


                                  July 24, 1998



General Binding Corporation
One GBC Plaza
Northbrook, Illinois 60062

                  Re:      Certain Federal Income Tax Consequences of the Offer
                           to Exchange 93/8% Senior Subordinated Notes Due 2008

Ladies and Gentlemen:

                  We have acted as counsel to General Binding Corporation, Inc.,
a Delaware corporation (the "Company"), in connection with its offer (the
"Exchange Offer") to exchange $1,000 principal amount of its 9 3/8% Senior
Subordinated Notes due 2008, for each $1,000 principal amount of its outstanding
9 3/8% Senior Subordinated Notes due 2008, as described in the Registration 
Statement on Form S-4 (the "Registration Statement"), which is being filed by
the Company with the Securities and Exchange Commission pursuant to the
Securities Act of 1933, as amended. The Registration Statement includes the
prospectus (the "Prospectus") relating to the Exchange Offer. Capitalized terms
not defined herein have the meanings specified in the Prospectus.

                  In rendering the opinion expressed below, we have examined the
Prospectus and such other documents as we have deemed relevant and necessary.
Such opinion is conditioned, among other things, upon the accuracy and
completeness of the facts, information and representations contained in the
Prospectus as of the date hereof and the continuing accuracy and completeness
thereof as of the date of the consummation of the Exchange Offer. We have
assumed that the transactions contemplated by the Prospectus and such other
documents will occur as provided therein and that there will be no material
change to the Prospectus or any of such other documents between the date hereof
and the date of the consummation of the Exchange Offer.

                  Based upon and subject to the foregoing, we are of the opinion
that the discussion set forth in the Prospectus under the caption "Certain
United States Federal Tax Considerations"


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[SIDLEY & AUSTIN LETTERHEAD]

General Binding Corporation
July 24, 1998
Page 2

constitutes, in all material respects, a fair and accurate summary of the
matters addressed therein, based upon current law and the assumptions stated or
referred to therein.

                  We assume no obligation to update or supplement this letter to
reflect any facts or circumstances which may hereafter come to our attention
with respect to the opinion expressed above, including any changes in applicable
law which may hereafter occur.

                  We hereby consent to the filing of this letter as an Exhibit
to the Registration Statement and to all references to our Firm included in or
made a part of the Registration Statement.

                                      Very truly yours,
 

                                      /s/ SIDLEY & AUSTIN