The consumer watchdog is calling for improvements in road and rail access to container ports.
The ACCC has been monitoring ports since major reforms were introduced following waterfront disputes in the 1990s.
Chairman Rod Sims says ports are performing well, with increased productivity leading to lower costs, but he says improvements in road and rail connections need to keep pace.
"The future issue that we have to address, and it needs broader policy issues to be looked at, is to make sure the land-side access keeps up," Mr Sims said.
"If it doesn't, that is a real productivity problem for the country."
The ACCC has identified three reforms it says should be considered to improve access to ports.
They include, peak period pricing to encourage trucks to arrive at ports at less busy times of the day, encouraging more rail use, as well as changes the way roads are paid for.
"At the moment, if industry wants to fund a road, because they see it's crucial to them, like a road to a port, at the moment they may want to pay to build a road, but there's no mechanism to get what they want to pay into the hands of the road construction entity so that it will actually build a road."
The Australian Trucking Association (ATA) acknowledges concerns about congestion on roads leading to ports, but ATA communications manager Bill McKinley says the ACCC's proposals won't work and changes to road funding arrangements would unfairly impact transport companies.
"Fundamentally it comes down to governments making better planning and road investment decisions," Mr McKinley says.
"The trucking industry needs to be able to use higher productivity vehicles, like B-Triples and, especially around the ports, super B-Doubles, so we can move the more freight with the same number of trucks."