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Except..there is never such reason. They can put the filter anywhere in the pipeline. Some even have it exactly where it should be: https://www.ifixit.com/Guide/2013+Subaru+Legacy+Oil+and+Oil+...

Mazda has historically been very good at designing for repairability. My (latest) Mazda is ten years old, so I cannot verify any model later than that, but it's one reason I've been brand-loyal for decades. The 2015 CX-5 puts the oil filter right next to the drain plug, slightly recessed (for protection, I assume), but with ample clearance around it for tool and finger access. It's the best thought-out oil filter location I've ever seen; I cannot think of any possible improvement. The advantage of that, over Subaru's choice, is that the oil in the filter can only ever spill into your drain pan (or I guess the ground, if you're a numpty), never into your engine compartment.

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