But they can make a headrests that do that. My car’s headrests can tilt forward or back depending on your preference. And it was made in the 2010’s, so it’s not like this is a super old, or new, development.
Making them adjustable makes the most sense as it allows people to adjust it to what they need, rather than just designing for the average person. The seats themselves are adjustable; you can slide them forward and back, up and down, some even tilt them forward or back. The headrests should be no different.