The usual reason is that if you want to use a 240/120V 3ph 4w Delta panel, any 2 pole BREAKERS that fit in it must be "straight 240V" rated, because there is a possibility that they can plug/bolt onto the B phase, where the maximum L-G reference is HIGHER than 120V. Therefore a panel that is designed for 240/120V 3ph 4w Delta systems is often designed with physical restrictions as to what type of branch breakers can be installed.
Most "standard" 2 pole breakers are rated 120/240V, meaning they NEVER see a L-G reference higher than 120V. So because, in a panel MADE for 208Y120V 3ph 4w, the L-G will never be more than 120V, they can use ANY breaker in the branch section. But if you were to then use it on 240/120V 3ph 4w Delta, the inappropriate branch breakers CAN fit in there, allowing for a potentially dangerous situation. So you CANNOT use a panel BUILT AS 208Y120V for a 240/120V 3 Ph 4W application.
You CAN by the way, go the other way. If you HAVE a panel BUILT for 240/120V 3ph 4w Delta, and you want to use it for 208Y120 3ph 4 w, that is OK.
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