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National Highway Traffic Safety Administration (NHTSA) revised the upper interior head-impact requirements of Federal Motor Vehicle Safety Standard (FMVSS) 201 to reduce abbreviated injury scale (AIS) 3 or greater injuries or fatalities during vehicle collisions. The more-stringent FMVSS 201 requirements have made both OEMs and material suppliers consider new design approaches and new materials with improved performance. This has led to development of several new trim-design options. In this paper we discuss the development of a new headliner substrate material that is believed will meet the FMVSS 201 head injury criterion (HIC) of 1000 or less - a value that is directly equivalent to the AIS 3 scale. Also discussed is how both a headform model and analytical methodology were used to evaluate this new material against existing headliner materials.