Yeah, I'm also pretty sure. You may run into different wiring situations though. The 2nd gen (06-10) use the TIPM electronics. So if you wanted heated seats and stuff like that, you'll run into issues. I also THINK the 2nd gen models have a sensor in the passenger seat for the air bag. Go to www.ptcruiserlinks.com, sign up and post your question. You'll need to sign in under the new member section first or you may not get your answers first. Just warning you. Most members are very helpful right off the bat, but there's a couple that don't want to help unless you first introduce yourself!