That strikes me as a pretty solid list, though I disclaim deep familiarity with the entire roster of the contenders. It catches the difference in tone from the '80s competitors (e.g. 16 Candles and the like).
As for the others mentioned: She's All That kind of strikes me as a more minor movie, a fairly uninspired reworking of the Pygmalion plot, and maybe even a bit of an '80s throwback. Never Been Kissed is mostly set in a High School and has its own take on the setting, but it's at least 60% not about teens.
Other possibilities:
Dazed and Confused presumably gets disqualified for being a period piece, rather than a "'90s movie."
Drive Me Crazy? I don't know. I've never seen it, which (accurately) suggests my impression is it's not that good.
There are a bunch more that are really something other than "teen comedies" in the vaguely pure sense: Encino Man might be close, Pleasantville is clearly something else, as are Detroit Rock City, Welcome to the Dollhouse, The Virgin Suicides (not entirely comic), All I Wanna Do/Strike/The Hairy Bird (very definitely period), uh ... Hoop Dreams?
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