Technically, it has never been a problem to format USB drives with a storage capacity of more than 32GB with the FAT32 file system. Only Windows itself has never been able to do this, so you always have to resort to external tools.
This is set to change in the future.
Last summer, Microsoft announced that the operating system’s internal format command would also support storage media up to 2TB with FAT32. Compared to the previous 32GB limit, this is more than 60 times as much.