In 1972, the National Highway Traffic Safety Administration (NHTSA) issued Federal Motor Vehicle Safety Standard No. 117 (Standard No. 117), a new safety standard requiring that seven pieces of information be permanently molded into the sidewalls of retreaded tires, including the maximum load, number of plies, size, and other characteristics. Separate regulations required retreaders to mark each tire with the name of the manufacturer and the week the retreading was completed. Secretary of Transportation Claude Brinegar (Secretary) (defendant) denied various petitions for reconsideration of Standard No. 117, stating that the NHTSA had relied on its own expertise and information to formulate the requirements and would not provide supporting documentation. The administrative record included evidence showing that the labeling requirement would be economically burdensome for the retreading industry. The National Tire Dealers and Retreaders Association, Inc. (NTDRA) (plaintiff) petitioned the United States Court of Appeals for the District of Columbia Circuit for review of Standard No. 117, arguing that the permanent-labeling instructions represented arbitrary agency action that should be set aside under section 10(e) of the Administrative Procedure Act (APA), 5 U.S.C. § 706.