The pulp and paper giant said it is "surprised" that an investigation that concerns accusations that the Chinese government provides subsidies to its domestic paper industries has been launched.
It has been instigated by Cepifine, the European association of fine paper producers, and according to APP it is the first anti-subsidy investigation against China by the EU.
However, Stuart Andrews, APP Europe's spokesman, described the allegations as "unfounded", and that it has serious concerns regarding the validity and legitimacy of the initiative.
"We will prove that our competitive advantage is the result of long term strategic investments, state-of-the-art technology and effective processes, fully in line with international trade law and practices."
Earlier this month, the European Commission launched an investigation after Chinese paper manufacturers were accused of selling coated fine paper into the European market at prices "below normal levels".
At the time, Frank Leerkotte, Cepifine managing director, said Chinese producers have been "very aggressive" and undercut prices by a "fantastically high amount".
He said: "Based on the information and evidence we have provided, the Commission has taken the difficult decision to launch an investigation.
"We are not looking for protection, but demand a level playing field. It is very obvious they are selling below cost price."
APP, the parent company of Chinese manufacturer Gold East China, strongly denied the accusations.
Andrews added that the combined effects of anti-dumping and anti-subsidy investigations form an "abuse of the trade defence instruments by certain European paper producers."
"The new wave of protectionism threatens to have negative consequences for EU industry and consumers," he said.
