6 switch rule

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Guess the OP has to tell us what we're talking about. Sub panel in most minds means there is a main panel somewhere with a breaker in it.



For a subpanel in a detached garage,

The sub is in a separate structure, at the sperate structure there can be no more than six disconnects. So typically that means use a main breaker panel or no more than six branch circuits from that panel

Or you could use a separate disconnecting means at the building and feed a MLO panel with as many branches as you want.
 
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