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                                                                     Exhibit 8.1

                                                      12 July 2001

Bunge Limited
50 Main Street
White Plains, New York 10606
U.S.A.

Dear Sirs

BUNGE LIMITED (THE "COMPANY")

We have acted as special legal counsel in Bermuda to the Company in connection
with the Registration Statement on Form F-1 (the "Registration Statement", which
term does not include any other document or agreement whether or not
specifically referred to therein or attached as an exhibit or schedule thereto)
filed with the U.S. Securities and Exchange Commission (the "Commission") on 12
July 2001 relating to the registration under the U.S. Securities Act of 1933, as
amended, of an aggregate of 17,600,000 common shares, par value US$0.01 per
share together with an additional 2,640,000 common shares, par value US$0.01 per
share subject to an over-allotment option granted to the underwriters by the
Company (together, the "Common Shares").

For the purposes of giving this opinion, we have examined a copy of the
Registration Statement. We have also reviewed the memorandum of association and
the bye-laws of the Company, each certified by the Secretary of the Company on
11 July 2001, copies of unanimous written resolutions of the members of the
Company and of the board of directors of the Company each dated 11 July 2001
(together, the "Minutes") and such other documents and made such enquires as to
questions of law as we have deemed necessary in order to render the opinion set
forth below.

We have assumed (a) the genuineness and authenticity of all signatures and the
conformity to the originals of all copies (whether or not certified) examined by
us and the authenticity and completeness of the originals from which such copies
were taken, (b) 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, (c) the accuracy and
completeness of all factual representations made in the Documents and other
documents reviewed by us, (d) that the resolutions contained in the Minutes
remain in full force and effect and have not been rescinded or amended.
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We have made no investigation of and express no opinion in relation to the laws
of any jurisdiction other than Bermuda (and assume that such laws would not have
any implication in relation to the opinions expressed herein). This opinion is
to be governed by and construed in accordance with the laws of Bermuda and is
limited to and is given on the basis of the current law and practice in Bermuda.
This opinion is issued solely for the purposes set out above and is not to be
relied upon in respect of any other matter.

On the basis of and subject to the foregoing, we are of the opinion that the
statements under the captions "Taxation" and "Legal Matters" in the prospectus
forming part of the Registration Statement, to the extent that they constitute
statements of Bermuda law, are accurate in all material respects and that such
statements constitute our opinion.

We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to our firm under the captions
"Taxation" and "Legal Matters".


Yours faithfully
/s/ CONYERS DILL & PEARMAN
