If you are not comfortable using command line, the format tool is a good choice, as it is more easy to use. You can use either Command Prompt or third-party FAT32 format tool to change file system to FAT32. There are several methods to format HDD or USB to FAT32 even when it is larger than 32GB.
Solutions to fix "The volume is too big for FAT32" If you copy a file larger than 4GB, you'll get error " File is too large for the destination file system".
This part explains limitations existing in FAT32 file system with Windows operating system, which can account for the volume too big issue.
I tried on Windows 7 computer, but FAT32 is not available.
"I' tried formatting my 500GB external hard drive to FAT32 so that I can use it on PS3. Though it's recommended to format disk into NTFS, some users still want to format removable disk to FAT32 in order to transfer files from Mac. Most computer users own more than one hard drives or external drives. However, if the hard drive is 1TB or larger, the formatting will give error "The volume is too big for FAT32". Windows can format a disk which is larger than 32GB to FAT32 with DOS command prompt. If you format a large partition or USB hard drive to FAT32 file system under Windows, you can only see NTFS or exFAT in the drop list for file system section. Symptom of "The volume is too big for FAT32" error