While not specifically listed in Part 43 Appendix A as a Preventative Maintenance task, the below letter of interpretation from the FAA does give the opinion that Appendix A is not intended to be a full list, but more representative of the tasks one might consider as major repairs, major alterations and preventative maintenance. As long as it doesn't involve complex disassembly/assembly to change the filter, I'd certainly consider it a preventative maintenance task.
"Similarly, for the same reason, we also believe that the following sentence in Advisory Circular 43-12A, Preventive Maintenance (which was referenced in Mr. Hernandez's letter), is overly restrictive. That sentence, found in Paragraph 3(b)(1), states: "If a task or maintenance function does not appear in the list, it is not preventive maintenance." As with the other paragraphs of Appendix A (i.e., on major repairs and major alterations), the lists are better viewed as examples of the tasks in each category-they cannot be considered all- inclusive. "
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2009/Coleal - (2009) Legal Interpretation.pdf