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Opinion of the Court
just rejected, that Congress defined "charge" as a verified accusation.
The other issue insignificant in this case, however prominent it is in much of the litigation that goes on over agency rulemaking, is the degree of deference owed to the regulation by reviewing courts. We agree with the Government as amicus that deference under Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U. S. 837, 843-844 (1984), does not necessarily require an agency's exercise of express notice-and-comment rulemaking power,7 see Brief for United States et al. as Amici Curiae 19, n. 11; we so observed in United States v. Mead Corp., 533 U. S. 218, 230- 231 (2001) ("[W]e have sometimes found reasons for Chevron deference even when no such administrative formality was required and none was afforded"). But there is no need to resolve any question of deference here. We find the EEOC rule not only a reasonable one, but the position we would adopt even if there were no formal rule and we were interpreting the statute from scratch. Because we so clearly agree with the EEOC, there is no occasion to defer and no point in asking what kind of deference, or how much.8
7 Title VII does not require the EEOC to utilize notice-and-comment procedures. Section 713(a) of Title VII requires the procedural regulations to "be in conformity with the standards and limitations" of the Administrative Procedure Act, 5 U. S. C. §§ 551-559. 42 U. S. C. § 2000e- 12(a) (1994 ed.). And the Administrative Procedure Act, 5 U. S. C. § 553(b), excepts "rules of agency organization, procedure, or practice" from notice-and-comment procedures unless required by statute.
8 We, of course, do not mean to say that the EEOC's position is the "only one permissible." See Commercial Office Products, 486 U. S., at 125 (O'Connor, J., concurring in part and concurring in judgment). The agency might, for example, have decided that the time to test the complainant's seriousness is before the agency expends any effort on the case, and so have required a verified complaint prior to interview. Justice O'Connor suggests, see post, at 122 (opinion concurring in judgment), that recognizing this implies that a sphere of deference is appropriate, and so resolves the Chevron question. But not all deference is deference under Chevron, see United States v. Mead Corp., 533 U. S. 218, 234 (2001),
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