Formatting 64 GB microSD(XC) card for FAT32. Using in phones, cameras, MP3 players?

[virtuality]

http://www.techrepublic.com/blog/windows-and-office/format-fat32-drives-beyond-32gb-limit/

So, if I format a 64 GB microSD(XC) card to FAT32 like this will I be able to use it in cameras, smartphones, MP3 players which theoretically only take microSD(HC) or up to 32 GB?

Why is the 32 GB limit so common even today?

 

[paperwastage]

Best is to Google product+64gb microsdxc and see if anyone has tried it

32gb is common either because the product was releasd before 64gb microsdxc came out in 2011, or they don't want to pay for the license that SDXC requires (exFat support), and hencce can't advertise as supporting sdxc officially