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# A Judge Said Engine Cleaner Is Not Fuel. The CPSC Just Agreed.
- URL: https://www.freemarketsreport.com/a-judge-said-engine-cleaner-is-not-fuel-the-cpsc-just-agreed/
- Published: 2026-10-16T01:56:50.000Z
- Updated: 2026-10-16T01:56:50.000Z
- Description: CPSC ruled engine cleaners and fuel stabilizers are not liquid fuels under the Portable Fuel Container Safety Act, 13 months after a federal court said so. The $545.7 million question, the bear case and one stock idea.
- Author: Michael A. Gayed, CFA

**A federal judge ruled that a can of engine cleaner is not fuel. The agency conceded in December and made it official today, thirteen months after the ruling. I think the three years of letters before that are the story, because that is what regulation by letter costs you.**

## Key Highlights

- **The action:** On October 15, 2026 the Consumer Product Safety Commission said fuel additives that clean engines, extend engine life, prevent weather-related effects or stabilize fuel are not "flammable liquid fuels" under the Portable Fuel Container Safety Act, so their containers need no flame mitigation device.[1](#fn-1)
- **The price tag:** CPSC puts the avoided cost at $545.7 million a year and up to $10.7 billion over 30 years, and says it found no reported flame-jetting incidents involving these additives.[1](#fn-1)
- **The ruling that started it:** On September 18, 2025 the U.S. District Court for the District of Minnesota granted summary judgment to Auto-Mark, Inc., which sells Sea Foam, and dismissed the case with prejudice.[2](#fn-2), [3](#fn-3)
- **The cost of waiting:** One manufacturer told the court that compliant closures would raise container costs by 300% and cost about $25 million to retool over a decade.[4](#fn-4)
- **The idea:** Energizer Holdings (ENR) sells STP fuel additives inside an Auto Care segment that posted $209.9 million of third-quarter net sales, up from $190.2 million.[5](#fn-5), [6](#fn-6)

Start with the object itself. You have probably bought it. A bottle of fuel stabilizer for the generator in the garage, a can of injector cleaner for the mower, a jug of winter deicer for a diesel truck. You pour it into something else. It is not what burns. It is what keeps the thing that burns from gumming up.

For about three years the federal government treated that bottle as a gas can.

## The surface story

Congress passed the Portable Fuel Container Safety Act in 2020 to stop a specific kind of accident. A flame reaches the spout of a gas can, travels inside, and the can jets fire or ruptures. The cure is a flame mitigation device, a small screen or valve that lets fuel out and keeps flame from getting in. The Act covers containers of five gallons or less meant for flammable liquid fuels with a flash point below 140 degrees Fahrenheit, and it names gasoline, kerosene, diesel, ethanol, methanol, denatured alcohol and biofuels.[2](#fn-2), [7](#fn-7)

That list is the whole point. Congress wrote the list. Congress did not write "and engine cleaners."

CPSC made the device mandatory in a rule finalized in January 2023, with enforcement originally slated for July 2023.[8](#fn-8) Then came the letter. On May 19, 2023 the commission's compliance office told industry the rule applied not only to the statutory fuels but also to "camp fuel, fire starters and accelerants, fuel additives, and engine cleaners." The judge later noted that the commission gave no specific reason for adding fuel additives and engine cleaners to the list.[9](#fn-9)

I want you to sit with how that worked. The agency did not amend the statute. It did not run a fresh rulemaking on additives. It answered a question in a letter, and the letter pulled a whole product category under a safety mandate that Congress had written for gasoline cans.

![Timeline of the fuel additive container fight from the January 2023 rule to the October 2026 CPSC action](https://storage.ghost.io/c/be/1b/be1bb8f3-f534-4eb9-b00d-09ff49598e5f/content/images/size/w1000/2026/10/chart1_timeline-3.png)

Source: ILMA, Jan. 8, 2026[8](#fn-8); CPSC enforcement discretion letter, July 11, 2025[10](#fn-10); Auto-Mark v. CPSC, order of Sept. 18, 2025[3](#fn-3); Feldman statement, Dec. 22, 2025[11](#fn-11); CPSC press release 27-034, Oct. 15, 2026[1](#fn-1).

## The quiet second document

Today's press release is the headline. The real document is the one from Minnesota.

Auto-Mark sells Sea Foam, a motor treatment company founded in 1942 that says it has sold hundreds of millions of cans. It sued under the Administrative Procedure Act and argued, among other things, that CPSC acted in excess of its statutory authority by regulating containers of non-fuel liquids.[12](#fn-12)

The court agreed on the first count. Judge Jeffrey Bryan looked at the products on the record and found they do not create heat or power on their own and cannot substitute for gasoline or diesel. He lined up four dictionary definitions of fuel, each built around a material burned to produce heat or power, and noted that the Environmental Protection Agency keeps separate registries for fuels and fuel additives. His conclusion was plain: the commission's definition expanded on the kinds of liquids Congress authorized it to regulate.[13](#fn-13)

That was the whole case. The judge found the statutory-authority argument enough and called the other counts, arbitrary rulemaking and vagueness, moot.[14](#fn-14)

Notice what is missing. The decision never asked whether flame-jetting is dangerous. It did not need to. It asked whether Congress gave the agency this power. Congress had not.

The government chose not to appeal. Acting Chairman Peter Feldman said on December 22, 2025 that the commission's earlier position "exceeded the agency's authority under the statute, was unsupported by incident data, and imposed significant and unnecessary costs".[11](#fn-11) The appeal was dismissed by joint stipulation that month.[2](#fn-2) The trade group ILMA called the district court's decision the controlling interpretation of the law once the appeal was dropped.[8](#fn-8)

So why today? Because a ruling in one district binds one case, and a company in another state still faces the same letter. Today's action makes the clarification the agency's own. Feldman had promised it in December, saying the commission would "make permanent any necessary regulatory clarifications".[11](#fn-11) Ten months later, it did.

## The numbers

CPSC says the action removes $545.7 million in annual regulatory costs and up to $10.7 billion over 30 years.[1](#fn-1) Those two figures are not the same thing, and the gap is worth a minute.

Multiply $545.7 million by 30 and you get $16.4 billion. The agency says $10.7 billion. The difference is a discount rate. I backed it out: a stream of $545.7 million a year for 30 years is worth about $10.7 billion today at a 3 percent discount rate. That is my arithmetic, not an agency statement, and CPSC did not publish the rate in the release I read. But it tells you the headline is a present value, and the plain annual number is the one a small company feels.

![Bars comparing undiscounted cumulative avoided cost with the same stream discounted at 3 percent over 5, 10, 20 and 30 years](https://storage.ghost.io/c/be/1b/be1bb8f3-f534-4eb9-b00d-09ff49598e5f/content/images/size/w1000/2026/10/chart2_pv.png)

Source: CPSC press release 27-034, Oct. 15, 2026[1](#fn-1). The 3 percent discounted series is my calculation from the $545.7 million annual figure; CPSC published only the annual and 30-year totals.

Now the company-level evidence, which comes from sworn declarations in the court record rather than from an agency estimate. Sea Foam said it found a closure supplier that could meet its volumes, but the closures would raise container costs by 300 percent and the retooling would cost roughly $25 million over a decade. Then the vendor said it could not make the closures in 2025.[4](#fn-4) Sea Foam also said there was only one testing facility in the country for the devices, and that the devices it piloted were impractical for its customers.[15](#fn-15) Those are a litigant's claims, so weigh them as such, but they are specific and they went into a federal record.

Here is the number I keep coming back to. Zero. Sea Foam told the commission it knew of no flame-jetting or container-rupture incident in more than 80 years.[16](#fn-16) CPSC now says it found none involving these additives.[1](#fn-1)

![Table of the key numbers in the fuel additive dispute and who reported each](https://storage.ghost.io/c/be/1b/be1bb8f3-f534-4eb9-b00d-09ff49598e5f/content/images/size/w1000/2026/10/chart3_table-1.png)

Source: CPSC press release 27-034, Oct. 15, 2026[1](#fn-1); Auto-Mark v. CPSC, order of Sept. 18, 2025[3](#fn-3).

## Who wins and who loses

The winners are easy to name. Every brand that sells a cleaner, stabilizer or deicer in a can no longer faces a closure redesign it could not source. Small brands benefit most, because a fixed redesign cost lands hardest on a firm that sells fewer cans. CPSC's own economic analysis said smaller manufacturers, many of which depend heavily on fuel additive sales, would have faced substantial packaging costs.[1](#fn-1)

The agency also deserves a sliver of credit it rarely gets. In July 2025 its own compliance office wrote that fuel additives can serve important safety roles in emergency preparedness, as stabilizers for generators and power tools and as deicers in harsh winters.[10](#fn-10) Read that sentence again. The agency was extending its own deadline to avoid shortages of products it described as safety tools.

The losers are quieter. If you were a supplier building compliant closures for additive cans, you lost a market that the statute never created. The same letter notes that industry had made progress on designs for these containers.[10](#fn-10) Today hurts if you were that supplier, and I do not pretend otherwise.

There is a second loser I find more interesting: the habit. For three years the commission ran this issue on enforcement discretion, a series of letters that extended the deadline in six-month and twelve-month blocks. The July 2024 letter pushed it to July 12, 2025\. The July 2025 letter pushed it to January 12, 2026.[10](#fn-10) Each extension was a favor. Each favor could be withdrawn, and the letter said so in plain words: the commission "may amend or rescind this enforcement discretion at any time".[10](#fn-10)

A permission slip is not a property right. A company that has to ask every six months whether it may keep selling a product cannot commit capital to it. That uncertainty has a price, and it never shows up in the $545.7 million.

## The free-market read

I want to be fair to the other side first, because the other side has a point. Flame jetting is real, and gas cans that burn children are a real harm. That is why Congress acted. Nothing in this action touches the gasoline can. CPSC says the existing device requirements for gasoline cans and other covered containers remain unchanged.[1](#fn-1) A safety agency that enforces the rule Congress wrote is doing its job.

The failure was the stretch. When an agency stretches a definition to sweep in things the legislature did not name, it replaces a decision that voters can argue about with a decision that only a lawyer can find. I would rather lose an argument in Congress than win one in a compliance letter.

Look at what the stretch did to price signals. A safety rule is supposed to price a risk. Here the rule priced a risk that, on this record, no one could point to. The cost was real: a closure that costs three times as much, a retooling bill in the tens of millions for one firm, a single test lab with a queue. Those costs flow into the shelf price of a bottle that people buy before a storm.

Pro-market does not mean pro-incumbent, and I should say where that bites. A rule like this one is a moat for the largest brands. A big company absorbs a fixed compliance cost across a huge volume, and the small one cannot. When you hear a large firm say it welcomes a new mandate, ask what it expects to lose less than its rivals. Today's relief runs the other way, which is part of why I like it.

The legal angle matters here too. The press release says the Supreme Court made clear in Loper Bright that agencies must follow the best reading of the law, not interpretations that expand their authority.[1](#fn-1) The Minnesota judge reached the result with dictionaries, not deference. That is the same tool in a smaller case. Two years ago an agency could have defended a stretched definition by calling it reasonable. It cannot do that now, and every agency that wrote a loose definition in a letter should be nervous. I wrote about the same mechanism when the FCC erased a cap that Congress wrote into law, in [The FCC Just Erased a Cap Congress Wrote Into Law](https://www.freemarketsreport.com/the-fcc-just-erased-a-cap-congress-wrote-into-law/), and when two circuits split over what a swap even is, in [Two Circuits Just Disagreed About What a Swap Is](https://www.freemarketsreport.com/two-circuits-just-disagreed-about-what-a-swap-is/). Definitions are where the power hides.

## The bear case

I could be wrong about how much this matters, and here is the case against me.

First, the action is a clarification, not a statute. A later commission could read the Act the other way, and the court ruling binds only the parties and persuades elsewhere. Congress could also amend the definition if it wanted additives covered. I would not bet on that, but the risk is not zero.

Second, the announcement came with no effective date, per the coverage I could find.[2](#fn-2) I have not seen the rule text. Until it is published I am relying on the agency's description of what it did, and the details of which product types qualify will matter. An additive with a low flash point, sold in a container a consumer might also use to store fuel, is a harder case than a cleaner that is not flammable at all.

Third, the safety record that CPSC cites is an absence, and an absence is only as good as the reporting system behind it. No reported incidents is not the same as no incidents. I take the point. It is also true that eighty years of Sea Foam cans and a federal agency that went looking for a hazard both came up empty, and that is evidence too.

Fourth, for investors, a rule that removes a cost does not guarantee a margin. Competition can pass the savings to consumers through lower shelf prices, and the brands that avoided a redesign may find that rivals avoided it too.

## The Idea: ENR (Energizer Holdings)

This is not advice, and you should treat it as a way to ask who is exposed to a policy change, not as a recommendation. I could not find a clean public pure play on fuel additives. So I looked for the cleanest public name with real fuel additive exposure, and I will tell you up front that it is an imperfect fit.

**What it does.** Energizer is best known for batteries, but it also sells automotive care products, including fuel and oil additives under the STP brand.[6](#fn-6) Its safety data sheet for STP Premium Fuel Stabilizer classifies the product as a category 4 flammable liquid with the hazard statement "combustible liquid".[17](#fn-17) Category 4 in the globally harmonized system begins above 60 degrees Celsius, which is 140 degrees Fahrenheit, so that classification sits outside the statute's below-140 definition. That is my reading of a safety data sheet, not a legal opinion, and other STP products may differ.

**Why the policy helps.** The causal chain is short. A closure redesign would have raised packaging cost and risked supply on a product line that sells into a seasonal, price-sensitive market. Removing the mandate removes that cost and that supply risk. The Auto Care segment posted third-quarter net sales of $209.9 million versus $190.2 million a year earlier, about 28.6 percent of the company's $734.1 million, and nine-month Auto Care sales of $473.7 million versus $464.4 million.[5](#fn-5) The release attributes Auto Care volume growth mainly to higher refrigerant distribution in North America[5](#fn-5), so I want to be clear that I cannot isolate fuel additive revenue. Energizer does not break it out in the release I read.

![Energizer third quarter net sales by segment, fiscal 2025 versus fiscal 2026](https://storage.ghost.io/c/be/1b/be1bb8f3-f534-4eb9-b00d-09ff49598e5f/content/images/size/w1000/2026/10/chart4_enr.png)

Source: Energizer fiscal 2026 third quarter results[5](#fn-5).

**What the market may be missing.** Maybe nothing, and that is the honest answer. The stock does not trade on this rule. Perplexity Finance shows ENR at $22.00 after the close on October 15 with a market capitalization of about $1.51 billion and a price-to-earnings ratio of 18.64.[18](#fn-18) Third-quarter adjusted earnings were $0.75 per share against $1.13 a year earlier, and the company moved its full-year outlook to the low end of its range.[5](#fn-5) The shares were down about 7.2 percent in the weeks after that report.[19](#fn-19) What I am pointing at is the cost avoided on one product line, a small tailwind for a business with other problems. The company guided fourth-quarter adjusted earnings of $1.25 to $1.35 per share and paid $0.30 a share in the quarter.[5](#fn-5) At $22, that dividend annualizes to about 5.5 percent, my arithmetic.

**The risks, and what proves it wrong.** The thesis is wrong if Energizer reports that fuel additives are an immaterial slice of Auto Care, which would make today's news a rounding error. It is wrong if the rule text excludes the STP products, or if a future commission reverses course. And it is wrong if battery margins keep falling, because batteries are the larger segment at $524.2 million of third-quarter sales, down from $535.1 million.[5](#fn-5) This is a modest, second-order idea. I would rather give you a modest honest one than a loud wrong one.

## What to watch next

Three things will tell you whether this holds.

First, the rule text. The press release has no effective date and no list of covered products. When the Federal Register notice appears, read the definition of an additive, because the boundary between a cleaner and a fuel is where the next dispute will start.

Second, the other letters. Fuel additives are one of several categories CPSC pulled in through guidance. If a court says a letter cannot expand a statute, every other product category that rests on a letter is a candidate for the same challenge.

Third, the next company to sue. Sea Foam took on a federal agency over a bottle and won in under a year. I expect more small manufacturers to read that docket. The agencies that wrote broad definitions without a statute behind them should assume somebody is reading it right now.

The judge needed one page of dictionary definitions to say what the agency spent three years refusing to hear. Congress wrote a list. The list did not include your garage.

## Sources

1. [CPSC press release 27-034, Oct. 15, 2026](https://www.cpsc.gov/Newsroom/News-Releases/2027/CPSC-Eliminates-Unnecessary-Fuel-Additive-Regulations-Saving-American-Businesses-Up-to-10-7-Billion?ref=freemarketsreport.com) (cpsc.gov)
2. [EconoTimes, Oct. 15, 2026](https://econotimes.com/CPSC-Exempts-Containers-for-Certain-Fuel-Additives-From-Flame-Device-Rule-1755246?ref=freemarketsreport.com) (econotimes.com)
3. [Auto-Mark v. CPSC, order of Sept. 18, 2025](https://cases.justia.com/federal/district-courts/minnesota/mndce/0:2024cv04442/221527/54/0.pdf?ref=freemarketsreport.com) (cases.justia.com)
4. [Auto-Mark v. CPSC, n.5](https://cases.justia.com/federal/district-courts/minnesota/mndce/0:2024cv04442/221527/54/0.pdf?ref=freemarketsreport.com) (cases.justia.com)
5. [Energizer fiscal 2026 third quarter results](https://investors.energizerholdings.com/2026-08-04-Energizer-Holdings,-Inc-Announces-Fiscal-2026-Third-Quarter-Results?ref=freemarketsreport.com) (investors.energizerholdings.com)
6. [Yahoo Finance, Energizer company profile](https://finance.yahoo.com/quote/ENR/profile/?ref=freemarketsreport.com) (finance.yahoo.com)
7. [CPSC portable fuel container FAQ](https://www.cpsc.gov/FAQ/Portable-Fuel-Container?ref=freemarketsreport.com) (cpsc.gov)
8. [ILMA, Jan. 8, 2026](https://ilma.org/cpsc-backs-away-from-regulating-pre-filled-fuel-additive-containers/?ref=freemarketsreport.com) (ilma.org)
9. [Auto-Mark v. CPSC, p. 8](https://cases.justia.com/federal/district-courts/minnesota/mndce/0:2024cv04442/221527/54/0.pdf?ref=freemarketsreport.com) (cases.justia.com)
10. [CPSC enforcement discretion letter, July 11, 2025](https://www.cpsc.gov/s3fs-public/PFCSA-Enforcement-Discretion-Extension-Letter-07-11-2025-Final.pdf?VersionId=NA656Zbm1rp6HdT8RgdA3aPFqW3iMwFA&ref=freemarketsreport.com) (cpsc.gov)
11. [Feldman statement, Dec. 22, 2025](https://www.cpsc.gov/About-CPSC/Chairman/Peter-A-Feldman/Statement/Statement-of-Acting-Chairman-Peter-A-Feldman-on-Auto-Mark-v-CPSC?ref=freemarketsreport.com) (cpsc.gov)
12. [Auto-Mark v. CPSC, pp. 2-6](https://cases.justia.com/federal/district-courts/minnesota/mndce/0:2024cv04442/221527/54/0.pdf?ref=freemarketsreport.com) (cases.justia.com)
13. [Auto-Mark v. CPSC, pp. 21-23](https://cases.justia.com/federal/district-courts/minnesota/mndce/0:2024cv04442/221527/54/0.pdf?ref=freemarketsreport.com) (cases.justia.com)
14. [Auto-Mark v. CPSC, n.15](https://cases.justia.com/federal/district-courts/minnesota/mndce/0:2024cv04442/221527/54/0.pdf?ref=freemarketsreport.com) (cases.justia.com)
15. [Auto-Mark v. CPSC, p. 8-9](https://cases.justia.com/federal/district-courts/minnesota/mndce/0:2024cv04442/221527/54/0.pdf?ref=freemarketsreport.com) (cases.justia.com)
16. [Auto-Mark v. CPSC, pp. 8-9](https://cases.justia.com/federal/district-courts/minnesota/mndce/0:2024cv04442/221527/54/0.pdf?ref=freemarketsreport.com) (cases.justia.com)
17. [Energizer safety data sheet, STP Premium Fuel Stabilizer](https://sds.chemdox.com/energizer/chemdox/document/ENR%203004%20SDS-02?ref=freemarketsreport.com) (sds.chemdox.com)
18. [Perplexity Finance, ENR quote and ratios](https://www.perplexity.ai/finance/ENR?ref=freemarketsreport.com) (perplexity.ai)
19. [Zacks via Yahoo Finance, Oct. 2026](https://finance.yahoo.com/markets/stocks/articles/why-energizer-enr-down-7-153012972.html?ref=freemarketsreport.com) (finance.yahoo.com)

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