Ah, I'd misremembered that.
Probably because it most often comes up in reference to Archivists, and since they're the one getting the benefit from the scroll creation, they're going to be the one footing the XP bill.
But you're right. Shadowhunter can be the crafter, then. He won't be required to be by Rashemi society until he himself gets a crafting feat, however.
Interesting.... Hathran are prohibited from having crafting feats, as they are socially prohibited from crafting items, but the rules actually allow them to be the crafters of items without having any crafting feats.....
I might well have to change that, just because it's so stupid.