Having tested around 100 cars all with similar seats and harnesses etc I have never even heard of this issue. I’ve had problems with upper seat belt anchorage points not high enough or strong enough, or the gap between headrest and seat being too much etc but never because the belts were not accessible.
You are allowed a degree of separation on the belts to simulate them coming over your shoulders so even going around the headrest should not be a problem. Although I usually come under the headrest with the harnesses.
I would certainly be asking for the testers ideas on how to solve this non problem.
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