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                          [KATTEN MUCHIN & ZAVIS LETTERHEAD]

                                                                     EXHIBIT 8.1

                                  October ___, 1998


Zebra Technologies Corporation
333 Corporate Woods Parkway
Vernon Hills, Illinois  60061

     Re:  Zebra/Eltron Merger -- Certain Federal Income Tax Consequences
          --------------------------------------------------------------

Ladies and Gentlemen:

     We have been requested to render this opinion concerning certain matters of
federal income tax law in connection with the proposed merger of Spruce
Acquisition Corp., a California corporation ("Merger Sub"), which is wholly
owned by Zebra Technologies Corporation, a Delaware corporation ("Parent"), with
and into Eltron International, Inc., a California corporation (the "Company"),
with the Company surviving the merger and becoming a wholly owned subsidiary of
Parent, (the "Merger"), and in accordance with that certain Agreement and Plan
of Merger dated as of July 9, 1998, among the Company, Parent and Merger Sub
(the "Agreement") and related documents and agreements referenced in the
Agreement (together with the Agreement, the "Merger Agreements").  Our opinion
is being delivered to you pursuant to Section 7.1(g) of the Agreement.

     Except as otherwise provided, capitalized terms referred to herein have the
meanings set forth in the Merger Agreements.  All section references, unless
otherwise indicated, are to the Internal Revenue Code of 1986, as amended (the
"Code").

     We have acted as legal counsel to Parent in connection with the Merger.  As
such, and for the purpose of rendering this opinion, we have examined (or will
examine on or prior to the Effective Time of the Merger) and are relying (or
will rely) upon (without any independent investigation or review thereof) the
truth and accuracy, at all relevant times, of the statements, covenants,
representations and warranties contained in the following documents (including
all schedules and exhibits thereto):

     1.   The Merger Agreements;

     2.   Representations made to us by Parent and Merger Sub, including those
          representations contained in that certain Parent Representation Letter
          dated October ___, 1998;
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     3.   Representations made to us by the Company, including those
          representations contained in that certain Company Representation
          Letter dated October ___, 1998;

     4.   The Proxy Statement prepared in connection with the Merger;

     5.   The Registration Statement on Form S-4 in connection with the Merger;
          and

     6.   Such other instruments and documents related to the formation,
          organization and operation of the Company, Parent and Merger Sub or
          the consummation of the Merger and the transactions contemplated
          thereby as we have deemed necessary or appropriate.

     In connection with rendering this opinion, we have assumed or obtained
certain representations (and are relying thereon, without any independent
investigation or review thereof) including, but not limited to, that:

     1.   Original documents (including signatures) are authentic; documents
          submitted to us as copies conform to the original documents, and there
          has been (or will be by the Effective Time of the Merger) due
          execution and delivery of all documents where due execution and
          delivery are prerequisites to the effectiveness thereof;

     2.   Any representation or statement referred to above made "to the
          knowledge of" or otherwise similarly qualified is correct without such
          qualification;

     3.   The Merger will be consummated pursuant to the Merger Agreements and
          will be effective under the applicable state law;

     4.   After the Merger, the Company will hold "substantially all" of its and
          Merger Sub's properties within the meaning of Section 368(a)(2)(E)(i)
          of the Code and the regulations promulgated thereunder;

     5.   Following the Merger, the Company will continue its historic business
          or use a significant portion of its historic business assets in a
          business;

     6.   At the time of the Merger, the Company will not have outstanding any
          warrants, options, convertible securities, or any other type of right
          which, if exercised or converted, would affect Parent's acquisition or
          retention of control of the Company, within the meaning of Section
          368(c) of the Code;
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     7.   Parent has no intention to reacquire any of its stock issued in the
          transaction;

     8.   Parent has no plan or intention to liquidate the Company, to merge the
          Company with or into another corporation, to sell or otherwise dispose
          of the Company Shares (except for transfers of stock to corporations
          controlled by Parent in accordance with Treas. Reg. Sections 
          1.368-2(k)(1) and (2)), or to cause the Company to sell or otherwise 
          dispose of its assets (except for dispositions made in the ordinary 
          course of business, or transfers of assets to a corporation controlled
          by the Corporation in accordance with Treas. Reg. Sections 
          1.368-2(k)(1) and (2));

     9.   No outstanding indebtedness of the Company, Parent or Merger Sub has
          represented or will represent equity for tax purposes (including,
          without limitation, any loans from Parent to the Company); no
          outstanding equity of the Company, Parent or Merger Sub has
          represented or will represent indebtedness for tax purposes; no
          outstanding security (other than the Company Option Plans defined in
          Section 4.1(c) of the Merger Agreement), instrument, agreement or
          arrangement that provides for, contains, or represents either a right
          to acquire the Company stock or to share in the appreciation thereof
          constitutes or will constitute "stock" for purposes of Section 368(c)
          of the Code;

     10.  There exists no intercorporate indebtedness between the Company and
          Parent or Merger Sub that was issued, acquired, or will be settled at
          a discount;

     11.  Each of the Company, Parent and Merger Sub has paid and will pay only
          its respective expenses, if any, incurred in connection with the
          Merger, and neither Parent, Merger Sub nor Company has agreed to
          assume, nor will it directly or indirectly assume, any expense or
          other liability, whether fixed or contingent, of any holder of Company
          Shares;

     12.  No more than 10% of the outstanding Company Shares shall be entitled
          to or exercise dissenter's rights.

     13.  Neither Parent, the Company nor Merger Sub is, or will be at the time
          of the Merger:  (a) an "investment company" within the meaning of
          Section 368(a)(2)(F) of the Code; or (b) under the jurisdiction of a
          court in a Title 11 or similar case within the meaning of Section
          368(a)(3)(A) of the Code.

     Based on our examination of the foregoing items and subject to the
assumptions, exceptions, limitations and qualifications set forth herein, it is
our opinion, as counsel for Parent and Merger Sub, that for federal income tax
purposes the Merger will constitute a 
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"reorganization" within the meaning of Section 368(a) of the Code, and the 
Company, Merger Sub and Parent will each be a party to such reorganization 
within the meaning of Section 368(b) of the Code.

     In addition to the assumptions set forth above, this opinion is subject to
the exceptions, limitations and qualifications set forth below:

     1.   This opinion represents and is based upon our best judgment regarding
          the application of federal income tax laws arising under the Code,
          existing judicial decisions, administrative regulations and published
          rulings and procedures.  Our opinion is not binding upon the Internal
          Revenue Service or the courts, and the Internal Revenue Service is not
          precluded from asserting a contrary position.  Furthermore, no
          assurance can be given that future legislative, judicial or
          administrative changes, on either a prospective or retroactive basis,
          would not adversely affect the accuracy of the opinion expressed
          herein.  Nevertheless, we undertake no responsibility to advise you of
          any new developments in the application or interpretation of the
          federal income tax laws.

     2.   Our opinion concerning certain of the federal tax consequences of the
          Merger is limited to the specific federal tax consequences presented
          above.  No opinion is expressed as to any transaction other than the
          Merger, including any transaction undertaken in connection with the
          Merger.  In addition, this opinion does not address any other federal,
          estate, gift, state, local or foreign tax consequences that may result
          from the Merger.  In particular, we express no opinion regarding:

          (a)  whether and the extent to which any Company stockholder who has
               provided or will provide services to the Company, Parent or
               Merger Sub will have compensation income under any provision of
               the Code;

          (b)  the effects of such compensation income, including, but not
               limited to, the effect upon the basis and holding period of the
               Parent Shares received by any such stockholder in the Merger;

          (c)  the potential application of the "disqualifying disposition"
               rules of Section 421 of the Code to dispositions of the Company
               Shares;

          (d)  the tax consequences of Parent's assumption of outstanding
               options to acquire the Company Shares on the holders of such
               options under any Company employee stock option or stock purchase
               plan;
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          (e)  the effects of the Merger on any pension or other employee
               benefit plan maintained by Parent or the Company;

          (f)  the potential application of the "golden parachute" provisions of
               Sections 280G, 3121(v)(2) and 4999 of the Code, the alternative
               minimum tax provisions of Sections 55, 56 and 57 of the Code or
               Sections 108, 305, 306, 357 and 424 of the Code, or the
               regulations promulgated thereunder;

          (g)  the tax consequences of the Merger to Parent, Merger Sub or the
               Company, including without limitation the recognition of any gain
               and the survival and/or availability, after the Merger, of any of
               the federal income tax attributes or elections of the Company or
               Parent (including, without limitation, foreign tax credits or net
               operating loss carryforwards, if any, of the Company or Parent),
               after application of any provision of the Code, as well as the
               regulations promulgated thereunder and judicial interpretations
               thereof;

          (h)  the basis of any equity interest in the Company acquired by
               Parent in the Merger;

          (i)  the tax consequences of any transaction in which Company Shares
               or a right to acquire Company Shares was received; and

          (j)  the tax consequences of the Merger (including the opinion set
               forth above) as applied to specific stockholders of the Company
               and/or holders of options or warrants to purchase Company Shares
               or that may be relevant to particular classes of the Company
               stockholders and/or holders of options or warrants for the
               Company Shares, including, without limitation, dealers in
               securities, corporate shareholders subject to the alternative
               minimum tax, foreign persons, and holders of shares acquired upon
               exercise of stock options or in other compensatory transactions.

     3.   No opinion is expressed if all the transactions described in the
          Merger Agreement are not consummated in accordance with the terms of
          such Merger Agreement and without waiver or breach of any material
          provision thereof or if all of the representations, warranties,
          statements and assumptions upon which we relied are not true and
          accurate at all relevant times.  In the event any one of the
          statements, representations, warranties or assumptions upon which we
          have relied to issue this opinion is incorrect, our opinion might be
          adversely affected and may not be relied upon.
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     4.   No ruling has been or will be requested from the Internal Revenue
          Service concerning the federal income tax consequences of the Merger.
          In reviewing this opinion, you should be aware that the opinion set
          forth above represents our conclusions regarding the application of
          existing federal income tax law to the instant transaction.  If the
          facts vary from those relied upon (including if any representation,
          covenant, warranty or assumption upon which we have relied is
          inaccurate, incomplete, breached or ineffective), our opinion
          contained herein could be inapplicable.  You should be aware that an
          opinion of counsel represents only counsel's best legal judgment, and
          has no binding effect or official status of any kind, and that no
          assurance can be given that contrary positions will not be taken by
          the Internal Revenue Service or that a court considering the issues
          would not hold otherwise.

     5.   We understand that counsel for the Company, Troy & Gould Professional
          Corporation, has rendered a tax opinion to the effect that the Merger
          will be accorded nonrecognition treatment except with respect to the
          payment of cash in lieu of fractional shares.

     6.   This opinion is being delivered solely for the purpose of satisfying
          the condition set forth in Section 7.1(g) of the Agreement.  This
          opinion may not be relied upon or utilized for any other purpose or by
          any other person or entity, including the Company and its
          shareholders, and may not be made available to any other person or
          entity, without our prior written consent.  We do, however, consent to
          the use of our name in the Registration Statement wherever it appears.


                                   Very truly yours,

                                   KATTEN MUCHIN & ZAVIS
