There is a substantial literature on fatigue among seafarers, but very little comparison of the experiences and perceptions of seafarers working for different companies and, in particular, those working for companies based in developed and developing countries. Using data from 880 questionnaires to seafarers and 60 interviews conducted with seafarers and managers, from two Chinese and two European shipping companies, this study takes a first step to addressing this gap. It reveals perceptions of higher fatigue, and poorer working and employment conditions, among seafarers working for Chinese as compared with European shipping companies. This difference was related to a relative lack of commitment from the Chinese shipping companies' managers to fatigue mitigation and a participatory approach. Overall, the findings suggest that although the merchant shipping industry has internationally regulated working and on-board living conditions, management practices and compliance standards within companies in different countries vary. International regulatory arrangements, therefore, do not result in a level playing field – which has potentially serious consequences both for seafarers' safety, health and wellbeing, and for the safety of the world's fleets and marine environments. The findings also indicate that, despite differences in degree, fatigue continues to be a significant problem across the shipping industry. Finally, ways are suggested in which stakeholders could contribute to improving fatigue mitigation and management.