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This article presents the results of research on the working time of hospital doctors in five European countries : Germany, Denmark, Lithuania, Spain, the United Kingdom. Its objective is to explain persistent working-time differences between and within various countries in spite of the existence of a European Directive. The authors’ explanation is three-fold : first, transposing the directive into national legislation gives rise to interpretations that diverge from European standards – more or less, depending on the country. Two series of factors are cited. On the one hand, the role of collective bargaining in each country generates differences according to the status of hospital doctors, types of hospitals and territories. On the other hand, the overall hospital setting definitely plays its part. Working time appears as a secondary issue in the surveyed countries : it is seen in the broader context of developments related to national hospital policies and medical demography. Issues raised by transposing the EU Directive on working time in the hospital sector should be understood in relation to such national specificities.