Yesterday, multiple sources reported that Nintendo Of America where selling "authentic Nintendo products" which included 3DS and DSi XL consoles with "minor cosmetic blemishes". The handhelds are guaranteed to be technically fully functional - "cleaned, tested, and inspected to meet Nintendo's high standards".
The prices currently range from $99 (£65) for a Metallic Rose or Midnight Blue DSi XL, up to $169 for an Aqua Blue or Midnight Purple 3DS with Zelda: Ocarina of Time 3D. These prices are cheaper than American store GameStop and are currently the best on the market.
In an interview with Eurogamer, a Nintendo of Europe spokesperson said "We currently have no plans and have made no announcements for this type of activity in Europe".
It is certainly a shame for European consumers, seeing as you'd be getting a second hand console at a cheaper price than stores such as Game and CEX, whom charge £100 and up just for a 3DS thats likely been traded in grubby with fingerprints and riddled with scratches.