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I don't think the argument "3C was NF therefore 3H can't be invitational" is valid. For example, 1D-1H-2C-2D-2NT is invitational (at any form of scoring including MPs), while 2C is NF.
Han, I'm going to have to beg to disagree here. There are substantial differences in these auctions.
Whereas 1D-1H-2C-2D-2N is invitational, it is the second bid that could be passed, i.e., 2C.
In the auction given, 1D-1H-2C-2H, it is now that opener must make some kind of invite - 2N, 3H, 2S would all show extra values and a move toward game. 3C could well end the auction, though, as responder with Jxx, KQxxxx, xx, Qx could easily pass - in essence, opener has made 2 non-forcing, non-invitaional bids - you are forced sometimes to make a non-forcing bid with extras, but the second time around you have to make up ground and show the extras.
I would take 3C in this auction to be a strong dislike for hearts, probably 2065 shape. With xx, A, AKxxx, AQxxx, it's better to bid 3H (or with agreement 2S).
So my point is you can certainly make one non-forcing bid and then invite, but it would be extremely odd to make two non-forcing bids and then still want to invite.
S - N
1♦-1♥
2♣-2♥*
3♣-3♦
3♥-...