Exhibit 8.1

List of Subsidiaries

List of Subsidiaries

Jurisdiction of Incorporation

Ownership

Subsidiaries

State Harvest Holdings Limited

British Virgin Island

100%

OAL SMY Limited

New Jersey, United States

100%

Beijing Origin State Harvest Biotechnology Limited

Peoples’ Republic of China

100%

Variable Interest Entity under State Harvest Holdings Limited (China)

Hainan Aoyu Biotechnology Limited

Peoples’ Republic of China

100%

Xinjiang Originbo Seed Company Limited

Peoples’ Republic of China

70.52%held by Hainan Aoyu

Subsidiaries held by Beijing Origin Sate Harvest Biotechnology Limited

Hubei Aoyu Agricultural Technology Limited

Peoples’ Republic of China

51%

Anhui Aoyu Zhonggye Technology Ltd.

Peoples’ Republic of China

50%

Xuzhou Aoyu Agricultural Technology Ltd.

Peoples’ Republic of China

51%

Shandong Aoyu Zhongye Limited

Peoples’ Republic of China

51%

Henan Aoyu Zhongye Limited

Peoples’ Republic of China

51%

Henan Baodao Origin Agriculture and Animal Husbandry Co., Ltd

Peoples’ Republic of China

51%

Shihezi Baodao Agriculture and Animal Husbandry Technology Co., Ltd

Peoples’ Republic of China

100% held by Baodao Origin

Beijing Origin Seed Limited

Peoples’ Republic of China

47% owned by Origin Biotechnology