About the Language Code for Comment and Unsynced Lyrics

True, yet it is not the same.
Comment gets the code added to a separate section in the field definition - that is why you can set it on the options.
This thread and post shows a hex dump of a comment fields with the added language token

The unsynced lyrics have the language token as part of the field data (only MP3) which is visible for programs that show the raw data (like MP3tag) - as it would be the task of the user to add the appropriate language token manually.