Exhibit (d)

                    LETTERHEAD OF THACHER PROFFITT & WOOD LLP

                                               November 3, 2008


Citibank, N.A.
ADR Department
388 Greenwich Street
New York, New York 10013

Ladies and Gentlemen:

      We have acted as U.S. counsel to Citibank, N.A. (the "Depositary") in
connection with the registration on Form F-6 (the "Registration Statement")
under the Securities Act of 1933 (the "Securities Act"), of American depositary
shares ("ADSs") evidenced by American depositary receipts ("ADRs"), each ADS
representing the right to receive five fully paid shares of common stock (the
"Shares") of Yue Yuen Industrial (Holdings) Ltd., a company incorporated under
the laws of Bermuda (the "Company").

      Subject to any provision of Bermudan law or regulation and the terms of
the Shares, we advise you that, when the Shares have been legally issued, we are
of the opinion that the ADSs, when issued in accordance with the terms of the
ADRs and the Registration Statement, will be legally issued and will entitle the
registered holders of the ADSs to the rights specified in the applicable ADRs.

      The foregoing opinion is limited to the laws of the State of New York and
the federal laws of the United States of America. We are expressing no opinion
as to the laws of any other jurisdiction.

      We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement. In giving such consent, we do not thereby admit that we
come within the category of persons whose consent is required under Section 7 of
the Securities Act.

                                                 Very truly yours,


                                                 /s/ Thacher Proffitt & Wood LLP