.
.
.
Exhibit 8.2
(CHINESE CHARACTERS)
GRANDALL LEGAL GROUP (SHANGHAI )
<Table>
(CHINESE CHARACTERS)
31ST FLOOR, NANZHENG BUILDING, 580 NANJING XILU, SHANGHAI, CHINA, 200041
(CHINESE CHARACTERS)/TEL.: (8621) 5234-1668 (CHINESE CHARACTERS)/FAX: (8621) 5234-1670
(CHINESE CHARACTERS)/E-MAIL: GRANDALL@SH163A.STA.NET.CN
(CHINESE CHARACTERS)/WEBSITE: HTTP://WWW.GRANDALL.COM.CN
</Table>
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July 14, 2008
Solarfun Power Holdings Co., Ltd.
666 Linyang Road,
Qidong City, Jiangsu Province,
People's Republic of China
RE: SOLARFUN POWER HOLDINGS CO., LTD.(FORM F-3)
Ladies and Gentlemen,
We are qualified lawyers of the People's Republic of China (the "PRC") and as
such are qualified to issue this opinion regarding the laws of the PRC. We are
serving as the PRC counsel of Solarfun Power Holdings Co., Ltd., a Cayman
Islands company incorporated as a limited liability company (the "Company"), and
have been requested to issue our opinion regarding PRC law in connection with
the filing of Form F-3 Registration Statement, as amended and supplemented (the
"Registration Statement"), filed by the Company with the United States
Securities and Exchange Commission under the Securities Act of 1933, as amended.
In delivering this opinion letter, we have reviewed and relied on the relevant
parts as detailed below of the Registration Statement.
In rendering the opinion described below, we have assumed the genuineness of all
the signatures, the legal capacity of natural persons, the authenticity of all
documents submitted to us whether submitted in original form, via electronic
communication, fax or other form of communication. We have also assumed that the
transactions related to the issuance of the securities registered under the
Registration Statement will be consummated in accordance with the terms of the
documents described herein.
Based upon the foregoing, and subject to the qualifications, assumptions and
limitations stated herein and in the Registration Statement, we are of the
opinion that the statements set forth in the Registration Statement, under the
caption "Taxation -
PRC Taxation" constitute an accurate summary of the matters described therein in
all material respects.
This opinion is rendered on the basis of the PRC laws (other than the laws of
Hong Kong, Macao or Taiwan) effective as at the date of this letter. We express
no opinion with respect to the transactions referred to herein or in the
Registration Statement other than as expressly set forth herein. We do not
express any opinion herein concerning any law other than the tax law of PRC
described above.
We hereby consent to the filing of this opinion letter as Exhibit 8.2 to the
Registration Statement and to the use of our name in the Registration Statement.
Sincerely yours,
/s/ Grandall Legal Group (Shanghai)
-----------------------------------
Grandall Legal Group (Shanghai)