Is my NNID region locked?

Maybe my question is a little dumb, but better be safe than sorry!

Currently I own an American region 3DS, but, I moved and I am now living in Europe.

In the sad event that I need to buy a new 3DS, for me be able to do a system transfer from my old 3DS to my new one so I don’t lose my games, DLCs and softwares (like my pokebank account), do I need my new 3DS to be american too?

I was thinking I could just use system transfer to the new European console and re-download my bought titles back at this new European 3DS, but I’m afraid now so it’s better to ask.

Thanks in advance!