I would say that it would rather depend on the oil filter o-ring seal profile / shape. An o-ring seal profile has to be torque flatten to a degree, to make a good / perfect seal. The oil seal profile of some oil filter brands are slightly rounded / higher profile, where as on other brands, this o-ring profile is almost flat in shape. It stands to reason that the flatter shape profile would require less flattening torque to make a good seal.