In the Material Design type scale, a sans serif typeface is used for the Subtitle 1 typography category.

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Subtitles are smaller than headlines. They are typically reserved for medium-emphasis text that is shorter in length. Serif or sans serif typefaces work well for subtitles.

Subtitles

Material Design Documentation

For subtitles, use caution when using expressive fonts, including display, handwritten, and script styles.

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