<DOCUMENT>
<TYPE>EX-8.2
<SEQUENCE>6
<FILENAME>dex82.txt
<DESCRIPTION>OPINION OF MINTZ,LEVIN
<TEXT>
<PAGE>

                                                                     EXHIBIT 8.2

                                  June 28, 2002

QIAGEN N.V.
Spoorstraat 501
5911 KJ Venlo
The Netherlands

Ladies and Gentlemen:

         You have requested our opinion regarding certain United States federal
income tax consequences of the ownership of the Common Shares (the "Shares") of
QIAGEN N.V., a Netherlands public limited liability company (the "Company"),
acquired pursuant to a public offering (the "Offering") of the Shares in the
United States.

         In formulating our opinion as to the matters certified, we have
examined such documents as we have deemed appropriate, including the
Registration Statement of the Company on Form F-3 as filed with the Securities
and Exchange Commission ("Commission") pursuant to the Securities Act of 1933
(the "Securities Act") on June ___, 2002 (such Registration Statement being
referred to hereinafter as the "Registration Statement") and the Company's
Annual Report on Form 20-F for the fiscal year ended December 31, 2001 as filed
with the Commission on April 2, 2002 (the "Form 20-F"). Also, we have obtained
such additional information as we have deemed relevant and necessary through
consultation with various officers and representatives of the Company.

         The terms of the Offering, which are set forth in the Registration
Statement, are incorporated herein by reference.

         Based upon the terms of the Offering, as set forth in the Registration
Statement, it is our opinion that the portion of the Form 20-F set forth under
the heading "Taxation - United States Federal Income Tax Considerations",
incorporated by reference into the Registration Statement, summarizes the
material United States federal income tax consequences to U.S. Holders and to
non-U.S. Holders (as defined therein) of the acquisition, ownership and
disposition of Shares acquired in the Offering.

         The foregoing opinion is based on current provisions of the United
States Internal Revenue Code of 1986, as amended, the Treasury Regulations
promulgated thereunder (including proposed Treasury Regulations), published
pronouncements of the Internal Revenue Service, and case law, any of which may
be changed at any time with retroactive effect. No opinion is expressed on any
matters other than those specifically referred to herein.

                                       1

<PAGE>

                                                                     EXHIBIT 8.2

         We hereby consent to your filing this opinion as an exhibit to the
Registration Statement and to the reference to our firm therein. We also consent
to the incorporation by reference of this opinion into any subsequent
registration statement filed pursuant to Rule 462(b) under the Securities Act in
connection with the offering to which the Registration Statement relates.

                         Very truly yours,

                         /S/ Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
                         -------------------------------------------------------

                         Mintz, Levin, Cohn, Ferris,
                           Glovsky and Popeo, P.C.

                                       2

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