The manufacturer?fs understanding is incorrect. There is an international understanding that the shipper must prepare and submit a Dangerous Goods Dec aration when shipping dangerous goods. This regulation has been set by UN ICAO (International Civil Aviation Organization) which Japan is a signatory.
In order to prepare and execute a Dangerous Goods Dec aration, the person must have been fully trained in the handling and preparation of dangerous goods shipments. Who should sign the Dec aration depends upon internal company rules. Some firms May designate only the CEO or the president to sign outgoing documents. Some firms May delegate the authority to lower echelon officers, i.e. division heads, department heads, etc. Who can sign an outgoing document depends upon the company?fs internal policy and has no bearing whether the person signing the document is a DG certificate holder.
Certainly, it will be ideal if the president himself possesses a DG certificate but such is not a requirement. DG certificate holders would prepare the Dec aration and whoever is authorized to sign outgoing documents on behalf of the company, will place his signature. If there is an error, the company will be held responsible for fines or for imprisonment. Preparing and signing a Dec aration with mediocre knowledge will be a threat to safety. Please advise that manufacturer to undergo proper dangerous goods training.
Japanese Dangerous Goods Transport Regulations come under the jurisdiction of Civil Aviation Bureau of the Ministry of Land, Infrastructure & Transportation while the manufacturers are governed by the Ministry of Economy, Trade & Industry. There is a certain amount of difference however since Japan is a signatory to ICAO, Japan must abide with ICAO rules.