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                             CONYERS DILL & PEARMAN


                          

                                ATTORNEYS AT LAW
CRICKET SQUARE, HUTCHINS DRIVE, P.O. BOX 2681, GRAND CAYMAN KY1-1111, CAYMAN ISLANDS
TEL: (345) 945 3901 FAX: (345) 945 3902 EMAIL: CAYMAN@CONYERSDILLANDPEARMAN.COM
                         WWW.CONYERSDILLANDPEARMAN.COM



                                                                     EXHIBIT 8.1

7 November 2007


<Table>
                                                     
Yingli Green Energy Holding Company Limited             DIRECT LINE: (852) 2842 9511
No. 3055 Middle Fuxing Road                             E-MAIL:      david.lamb@conyersdillandpearman.com
Baoding 071051                                          OUR REF:     DML/lg/251040 (M#872004)
People's Republic of China                              YOUR REF:
</Table>


Dear Sirs,

YINGLI GREEN ENERGY HOLDING COMPANY LIMITED (THE "COMPANY")

We have acted as special Cayman legal counsel to the Company in connection with
the follow-on public offering on the New York Stock Exchange of American
Depositary Shares representing ordinary shares issued by the Company (the
"Shares") and the offer and sale of such number of ordinary shares of the
Company by certain selling shareholder(s) of the Company as described in the
prospectus contained in the Company's registration statement on Form F-1, as
amended (the "Registration Statement" which term does not include any exhibits
thereto) filed by the Company under the United States Securities Act of 1933
(the "Securities Act") with the United States Securities and Exchange Commission
(the "Commission").

For the purposes of giving this opinion, we have examined and relied upon copies
of the following documents:

(i)  the Registration Statement to be filed by the Company under the Securities
     Act with the Commission, as amended; and

(ii) a draft of the prospectus (the "Prospectus") contained in the Registration
     Statement.

We have also reviewed and relied upon (1) the third amended and restated
memorandum of association and the third amended and restated articles of
association of the Company, (2) a copy of an undertaking from the
Governor-in-Council of the Cayman Islands under the Tax Concessions Law (1999
Revision) dated August 15, 2006, issued in favour of the Company and (3) such
other documents and made such enquiries as to questions of law as we have deemed
necessary in order to render the opinion set forth below.

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                                                        (CONYERS DILL & PEARMAN)
Yingli Green Energy Holding Company Limited
7 November 2007

We have assumed (i) the genuineness and authenticity of all signatures, stamps
and seals and the conformity to the originals of all copies of documents
(whether or not certified) examined by us and the authenticity and completeness
of the originals from which such copies were taken; (ii) that where a document
has been examined by us in draft form, it will be or has been executed and/or
filed in the form of that draft, and where a number of drafts of a document have
been examined by us all changes thereto have been marked or otherwise drawn to
our attention, and (iii) the accuracy and completeness of all factual
representations made in the Prospectus and Registration Statement and other
documents reviewed by us.

We have made no investigation of and express no opinion in relation to the laws
of any jurisdiction other than the Cayman Islands. This opinion is to be
governed by and construed in accordance with the laws of the Cayman Islands and
is limited to and is given on the basis of the current law and practice in the
Cayman Islands.

On the basis of and subject to the foregoing, we are of the opinion that the
statements relating to certain Cayman Islands tax matters set forth under the
caption "Taxation - Cayman Islands taxation" in the Prospectus forming part of
the Registration Statement, to the extent that they constitute statements of
Cayman Islands law, are accurate in all material respects and that such
statements constitute our opinion.

We hereby consent to the filing with the Securities and Exchange Commission of
this letter as an exhibit to the Registration Statement of which the Prospectus
is a part, and the reference to us under the captions "Taxation", "Legal
Matters" and "Enforceability of Civil Liabilities" in the Prospectus contained
in the Registration Statement. In giving the foregoing consent, we do not admit
that we are experts within the meaning of Section 11 of the Securities Act or
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
promulgated thereunder.



Yours faithfully,


/s/ Conyers Dill & Pearman

Conyers Dill & Pearman

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