I was deploying new Salesforce workflows via Eclipse from one sandbox to another and then I got this error for several of them. The number is a variable here of course.
salesforce Exceeded maximum number (10) of active workflows
The strange thing is that this is no limit. I have seen cases on the Internet with the number 70 here. I myself got other cases with 3. So I don’t know why this error message pops up but I know how to get around it – a workaround.
Modify the active tag of the workflows. I.e. set them to false, see below. I.e. this is done in the xml-representation of the workflows in Eclipse:
<active>false</active>
Then deploy to the other ORG. The workflows will get created. Now you modify the active flag back to true and deploy again.
