Exhibit 8.1

HARNEYS

British Virgin Islands lawyers

			Harney Westwood & Riegels LLP 5th Floor, 5 New Street Square London EC4A 3BF Tel: +44 (0) 20 7842 6080 Fax: +44 (0) 20 7353 0487 www.harneys.com
25 June 2009			Your Ref

			Our Ref 039181.0006.RAG

BY EMAIL AND POST			Doc ID 72582_1

ReneSola Ltd

No. 8 Baoqun Road, Yaozhuang

Jiashan, Zhejiang 314117

People’s Republic of China

Dear Sirs

ReneSola Ltd, Company No. 1016246 (the “Company”)

Registration Statement on Form F-3

We are lawyers qualified to practise in the British Virgin Islands and have been asked to advise in connection with the Company’s preparation of a Registration Statement (the “Registration Statement”) on Form F-3 to be filed on the date hereof by the Company with the United States Securities and Exchange Commission (the “Commission”) under the United States Securities Act of 1933, as amended, relating to the issuance and sale from time to time by the Company of shares of no par value (“Shares”) and/or in the form of American depositary shares each representing two Shares.

2.	For the purpose of this opinion, we have examined the following documents and records:

(a)

a final draft copy of the Registration Statement;

(b)

a final draft copy of the prospectus contained in the Registration Statement;

(c)

a copy of the Memorandum and Articles of Association and Certificate of Incorporation of the Company obtained from the British Virgin Islands Registry of Corporate Affairs on 18 June 2009;

(d)

information revealed by our searches of:

(i)

the records and information certified by Harneys Corporate Services Limited, the registered agent of the Company, on 8 June 2009 of the statutory documents and records maintained by the Company at its registered office;

Harney Westwood & Riegels LLP is a limited liability partnership registered in England & Wales

Reg. No. OC302285 VAT No. 795563084

A list of partners is available for inspection at our offices.

British Virgin Islands | Cayman Islands | Anguilla | London | Hong Kong

(ii)

the public records of the Company on file and available for inspection at the Registry of Corporate Affairs, Road Town, Tortola, British Virgin Islands on 24 June 2009; and

(iii)

the records of proceedings on file with, and available for inspection on 24 June 2009 at the High Court of Justice, British Virgin Islands,

(the “Searches”).

The above are the only documents or records we have examined and the only enquiries we have carried out. In particular we have made no enquiries as to matters of fact other than the Searches.

3.	For the purposes of this opinion we have assumed without further enquiry:

(a)

the authenticity of all documents submitted to us as originals, the conformity with the originals of all documents submitted to us as copies and the authenticity of such originals;

(b)

the genuineness of all signatures and seals;

(c)

the accuracy and completeness of all corporate minutes, resolutions, certificates and records which we have seen;

(d)

that the information indicated by the Searches is and remains true and correct;

(e)

the accuracy of any and all representations of fact expressed in or implied by the documents we have examined.

4.	Based on the foregoing, and subject to the qualifications expressed below, our opinion is as follows:

Taxation. The statements relating to certain British Virgin Islands tax matters set forth under the heading Item 10.E — Additional Information — Taxation” in the Company’s annual report on Form 20-F for the year ended December 31, 2008 filed with the Commission on June 10, 2009 (the “Annual Report”), which is incorporated by reference into and forms part of the Registration Statement, to the extent that they constitute statements of British Virgin Islands law, are accurate in all material respects and that such statements constitute our opinion.

5.	This opinion is confined to and given on the basis of the laws of the British Virgin Islands as they are in force at the date of this opinion. We have made no investigation of, and express no opinion on, the laws of any other jurisdiction.

We hereby consent to the filing of this opinion with the Commission as an exhibit to the Registration Statement and to the references made to us under the headings “Item 10.E. — Additional Information — Taxation” and “Item 16G. — Corporate Governance” in the Annual Report which is incorporated by reference into the Registration Statement.

Yours faithfully

HARNEY WESTWOOD & RIEGELS LLP

/s/ Harney Westwood & Riegels LLP