Exhibit 8.1


                           (SHEARMAN & STERLING LLP)
                 1080 MARSH ROAD | MENLO PARK | CA | 94025-1022
            WWW.SHEARMAN.COM | T +1.650.838.3600 | F +1.650.838.3699



                                                                   June 27, 2008


Solarfun Power Holdings Co., Ltd.
666 Linyang Road
Qidong, Jiangsu Province 226200
Peoples Republic Of China

Ladies and Gentlemen:

We are acting as counsel to Solarfun Power Holdings Co., Ltd., an exempted
company with limited liability incorporated in the Cayman Islands (the
"Company"), in connection with the preparation of the registration statement on
Form F-3 (the "Registration Statement") and the related preliminary prospectus
(the "Prospectus") with respect to the registration by the Company of
$172,500,000 aggregate principal amount of 3.50% Convertible Senior Notes due
2018 (the "Notes") and the ordinary shares (the "Ordinary Shares") underlying
the American Depositary Shares (the "ADSs") that are issuable upon conversion of
the Notes, for resale by the holders of the Notes. The Company is filing the
Registration Statement with the Securities and Exchange Commission (the
"Commission") under the Securities Act of 1933, as amended (the "Act"). Any
defined term used and not defined herein has the meaning given to it in the
Prospectus.

For purposes of the opinion set forth below, we have, with the consent of the
Company, relied upon the accuracy of the Registration Statement and the
Prospectus.

Based upon and subject to the foregoing, and based upon the U.S. Internal
Revenue Code of 1986, as amended (the "Code"), the Treasury regulations
promulgated thereunder, judicial decisions, revenue rulings and revenue
procedures of the U.S. Internal Revenue Service (the "IRS"), and other
administrative pronouncements, all as in effect on the date hereof, it is our
opinion that, subject to the limitations set forth therein, the discussion
contained in the Prospectus under the caption "Taxation -- U.S. Federal Income
Taxation" is an accurate summary of the material U.S. federal income tax
consequences to U.S. Holders of the acquisition, ownership and disposition of
the Notes, the ADSs and the Ordinary Shares under currently applicable law. We
adopt such discussion as our opinion.

Our opinion is based on current U.S. federal income tax law and administrative
practice, and we do not undertake to advise you as to any future changes in U.S.
federal income tax law or administrative practice that may affect our opinion
unless we are specifically retained to do so. Further, legal opinions are not
binding upon the IRS and there can be no assurance that contrary positions may
not be asserted by the IRS.



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HONG  KONG  |  LONDON  |  MENLO  PARK |  MUNICH NEW  YORK  |  PARIS  |  ROME  |
SAN   FRANCISCO   |  SAO  PAULO  |  SHANGHAI  |   SINGAPORE   |  TOKYO  |
TORONTO  |  WASHINGTON, DC

SHEARMAN & STERLING LLP IS A LIMITED LIABILITY PARTNERSHIP ORGANIZED IN THE
UNITED STATES UNDER THE LAWS OF THE STATE OF DELAWARE, WHICH LAWS LIMIT THE
PERSONAL LIABILITY OF PARTNERS.


Solarfun Power Holdings Co., Ltd.                                  June 27, 2008
Page 2


We hereby consent to the filing of this opinion with the Commission as an
exhibit to the Registration Statement and to the reference to us in the
Prospectus. In giving such consent, we do not hereby admit that we are in the
category of persons whose consent is required under Section 7 of the Act and the
rules and regulations of the Commission promulgated thereunder.

Very truly yours,

SHEARMAN & STERLING LLP



/s/ SHEARMAN & STERLING LLP

LEC

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