That represents a drop of 48 from the same stage of the 2016 tournament in France.
Scotland committed only six fouls in their defeat by the Czech Republic while North Macedonia's 16 against Austria was the most of any of the 20 teams to play.
Eight sides avoided a yellow card in their opening game while the only red card was shown to Poland's Grzegorz Krychowiak in their defeat by Slovakia.
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Home/Sports/Football/Keep It Clean - Euro 2020 Has Fewest Fouls After 10 Games