Usually, the HVAC is not designed to cool the cargo area, even if it is a station wagon or hatcback or SUV (basically a vehicle with an open cargo area). I've been told that the 3-series A/C is quite strong, though so I would imagine that if you just run the A/C on full blast for a while, it should be able to cool the cargo area decently (although not as cold as the cabin would be).