Then find one that isn't so low. Or, you could try shortening up the tether a bit.
Another option you have is to simply hand her the toy instead of dangle it in front of her face. If she's too little to hold onto the toy, she's probably too little to really care if one is there or not.
Don't most car seats say that you need to recline the handle when in the car, though, rather than leave it up to hang toys from?